Supreme Court Reiterates Concrete Injury Requirement in Consumer Class Action Statutory Damages Case

摘要

The U.S. Supreme Court recently issued a 6-2 decision in Spokeo, Inc. v. Robins, a case closely followed by the class action bar to see how high a hurdle Article Ⅲ's constitutional standing requirement is in class actions seeking large damages for alleged technical or procedural statutory violations that cause no actual injury. The Court made clear that Congress cannot manufacture Article Ⅲ standing simply by creating statutory rights enforced by private rights of action. Instead, the Court reaffirmed its longstanding doctrine that a private litigant must assert at the pleading stage an injury that is not only "particularized" but also sufficiently "concrete" to present an actual case or controversy for a federal court to resolve.