LOCATION: Spokeo, Inc. Headquarters
DOCKET NO.: 13-1339
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Ninth Circuit
CITATION: 578 US (2016)
GRANTED: Apr 27, 2015
ARGUED: Nov 02, 2015
DECIDED: May 16, 2016
Andrew J. Pincus – for the petitioner
Malcolm L. Stewart – Deputy Solicitor General, for the United States as amicus curiae, for the respondent
William S. Consovoy – for the respondent
Facts of the case
Spokeo, Inc. (Spokeo) operated a website that provided information about individuals such as contact data, marital status, age, occupation, and certain types of economic information. Thomas Robins sued Spokeo and claimed that the company willfully violated the Fair Credit Reporting Act (FCRA) by publishing false information about him on the website. However, Robins was unable to allege any “actual or imminent harm,” so the district court granted Spokeo’s motion to dismiss for lack of subject-matter jurisdiction and Robins’ lack of standing under Article III of the Constitution. Robins then filed an amended complaint in which he alleged that he suffered actual harm to his employment prospects due to the website falsely claiming that he was wealthy. The district court originally denied Spokeo’s motion to dismiss but later reconsidered its order and dismissed the complaint for failure to state an injury in fact. Robins appealed and argued that the district court could not reconsider its previous decision and that he had sufficiently alleged an injury in fact to qualify for Article III standing. The U.S. Court of Appeals for the Ninth Circuit reversed and held that, although the district court could reconsider its ruling, the allegation of a violation of a statutory right is sufficient injury to qualify for standing.
Can Congress authorize a cause of action based on a violation of a federal statute and therefore confer Article III standing on a plaintiff who has not suffered concrete harm?
Media for Spokeo, Inc. v. Robins
Audio Transcription for Opinion Announcement – May 16, 2016 in Spokeo, Inc. v. Robins
John G. Roberts, Jr.:
Justice Alito has our opinion in case 13-1339, Spokeo versus Robins.
Samuel A. Alito, Jr.:
This case concerns standing to sue under Article III of the Constitution.
Respondent Robbins sued petitioner Spokeo which operates a so-called people search engine.
Robbins claimed that a Spokeo search for his name yielded inaccurate information and that Spokeo violated his rights under the Fair Credit Reporting Act.
The District Court dismissed the complaint holding that Robbins failed to plead injury in fact which is a requirement for Article III Standing.
The Ninth Circuit reversed and remanded because Robbins had alleged that Spokeo had violated his personal statutory rights and because he had an individualized interest in the handling of his credit information.
We now vacate the decision of the court below and remand.
The Ninth Circuit properly considered whether Robbins had alleged a particularized injury, but it erred when it did not also consider whether the alleged injury was sufficiently concrete.
Justice Thomas has filed a concurring opinion; Justice Ginsburg has filed a dissenting opinion in which Justice Sotomayor has joined.