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SPOKEO, INC. V. ROBINS 578 U.S. ___ (2016)

The Fair Credit Reporting Act of 1970 (FCRA) requires consumer reporting agencies to "follow reasonable procedures to assure maximum possible accuracy of" consumer reports and imposes liability on any person "who willfully fails to comply with any requirement" of the act. After respondent Thomas Robins discovered that his Spokeogenerated profile contained inaccurate information, he filed a federal class-action complaint against Spokeo Inc., alleging that the company willfully failed to comply with the FCRA's requirements. The district court dismissed Robins' complaint. The Ninth Circuit reversed. Justices Roberts, Kennedy, Thomas, Breyer, and Kagan joined the majority opinion. Justice Ginsburg filed a dissenting opinion, in which Sotomayor joined. ALITO, J.: This case presents the question whether respondent Robins has standing to maintain an action in federal court against petitioner Spokeo under the Fair Credit Reporting Act of 1970 . . . Spokeo operates a "people search engine." If an individual visits Spokeo's Web site and inputs a person's name, a phone number, or an e-mail address, Spokeo conducts a computerized search in a wide variety of databases and provides information about the subject of the search. Spokeo performed such a search for information about Robins, and some of the information it gathered and then disseminated was incorrect. When Robins learned of these inaccuracies, he filed a complaint on his own behalf and on behalf of a class of similarly situated individuals. The District Court dismissed Robins' complaint for lack of standing, but a panel of the Ninth Circuit reversed. The Ninth Circuit noted, first, that Robins hadpage 79 alleged that "Spokeo violated his statutory rights, not just the statutory rights of other people," and, second, that "Robins's personal interests in the handling of his credit are individualized rather than collective." Based on these two observations, the Ninth Circuit held that Robins had adequately alleged injury in fact, a requirement for standing under Article III of the Constitution. This analysis was incomplete. As we have explained in our prior opinions, the injury-in-fact requirement requires a plaintiff to allege an injury that is both "concrete and particularized." The Ninth Circuit's analysis focused on the second characteristic (particularity), but it overlooked the first (concreteness). We therefore vacate the decision below and remand for the Ninth Circuit to consider both aspects of the injury-in-fact requirement. . . . Standing to sue is a doctrine rooted in the traditional understanding of a case or controversy. The doctrine developed in our case law to ensure that federal courts do not exceed their authority as it has been traditionally understood. The doctrine limits the category of litigants empowered to maintain a lawsuit in federal court to seek redress for a legal wrong . . . In this way, "[t]he law of Article III standing . . . serves to prevent the judicial process from being used to usurp the powers of the political branches," and confines the federal courts to a properly judicial role. To establish injury in fact, a plaintiff must show that he or she suffered "an invasion of a legally protected interest" that is "concrete and particularized" and "actual or imminent, not conjectural or hypothetical." . . . For an injury to be "particularized," it "must affect the plaintiff in a personal and individual way." . . . Particularization is necessary to establish injury in fact, but it is not sufficient. An injury in fact must also be "concrete." . . . A "concrete" injury must be "de facto"; that is, it must actually exist . . . In the context of this particular case, these general principles tell us two things: On the one hand, Congress plainly sought to curb the dissemination of false information by adopting procedures designed to decrease that risk. On the other hand, Robins cannot satisfy the demands of Article III by alleging a bare procedural violation. A violation of one of the FCRA's procedural requirements may result in no harm. For example, even if a consumer reporting agency fails to provide the required notice to a user of the agency's consumer information, that information regardless may be entirely accurate. In addition, not all inaccuracies cause harm or present any material risk of harm. An example that comes readily to mind is an incorrect zip code. It is difficult to imagine how the dissemination of an incorrect zip code, without more, could work any concrete harm. Because the Ninth Circuit failed to fully appreciate the distinction between concreteness and particularization, its standing analysis was incomplete. It did not address the question framed by our discussion, namely, whether the particular procedural violations alleged in this case entail a degree of risk sufficient to meet the concreteness requirement. We take no position as to whether the Ninth Circuit's ultimate conclusionthat Robins adequately alleged an injury in factwas correct. The judgment of the Court of Appeals is vacated, and the case is remanded for proceedings consistent with this opinion.