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13-1339 SPOKEO V. ROBINS DECISION BELOW: 742 F.3d 409 CERT. GRANTED 4/27/2015 QUESTION PRESENTED: Whether Congress may confer Article III standing upon a plaintiff who suffers no concrete harm, and who therefore could not otherwise invoke the jurisdiction of a federal court, by authorizing a private right of action based on a bare violation of a federal statute. LOWER COURT CASE NUMBER: 11-56843
The U.S. Supreme Court case Spokeo, Inc. v. Robins in 2015 revolved around the issue of whether or not a person has the legal right to sue a company for violating federal law if they cannot prove that they were directly harmed by this violation. Thomas Robins sued Spokeo, an online people search engine, under the Fair Credit Reporting Act (FCRA), claiming it published incorrect information about him which could potentially harm his employment prospects. However, he did not provide evidence of actual harm done to him due to these inaccuracies. The Supreme Court ruled in favor of Spokeo and sent the case back down to lower courts for further proceedings because while Congress can create statutory rights and violations thereof can cause injury sufficient enough for standing before court; such injury must be both particularized and concrete - something Robbins failed to demonstrate adequately.
In the dissenting opinion for Spokeo, Inc. v. Robins, Justice Ginsburg argued that Thomas Robins had sufficiently demonstrated concrete harm to establish standing under Article III of the Constitution. She contended that Spokeo's inaccurate reporting of his personal information was not a mere technical violation of the Fair Credit Reporting Act (FCRA), but rather it could affect his job prospects and cause him financial or reputational harm. Therefore, she disagreed with the majority's decision to remand the case back to lower courts for further proceedings on whether Robins' injury was "concrete." In her view, Congress enacted FCRA specifically to curb actions like those taken by Spokeo and thus intended such violations as injuries in their own right.