Spokeo v. Robins, which DWT has written about previously.
Spokeo held that plaintiffs must establish a concrete injury even in the context of a statutory violation. The named plaintiff in that case alleged that Spokeo had violated the FCRA by publishing incorrect information about him on the internet and harming his employment prospects.
While the Ninth Circuit had found the violation of a statutory right sufficient to confer standing, the U.S. Supreme Court disagreed, holding that a bare procedural violation, such as an incorrect zip code,
1 could not qualify as a concrete injury. In making this determination, the Court considered Congress's intent to elevate an injury to a concrete harm, and whether the alleged injury bears a close relationship to a harm that has traditionally been recognized in common law.