Claims Arising Under 15 U.S.C. § 1681b(b)(1)(A) — The Certification Requirement - Consumer Protection
In the years following the Supreme Court's decision in Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1549 (2016) — which held that "bare procedural violation[s], divorced from any concrete harm, [do not] satisfy the injury-in-fact requirement of Article III" — district courts have had to grapple with the question of standing under the Fair Credit Reporting Act (FCRA), 15 U.S.C. § 1681, et seq., and in particular, what injuries resulting from an alleged violation of FCRA are sufficiently concrete to invoke Article III standing. This blog post discusses claims arising under Section 1681b(b)(1)...