Robins v. Spokeo, Inc., No. 11-56843 (9th Cir. 2014)Annotate this Case
Plaintiff filed suit against Spokeo, operator of a website that provides users with information about other individuals, for willful violations of the Fair Credit Reporting Act (FCRA), 15 U.S.C. 1681 et seq. Because the district court had neither been divested of jurisdiction nor submitted this case to the jury, it was free to reconsider its own prior ruling. Therefore, the court concluded that the law-of-the-case doctrine did not limit the district court in its final order. The court also concluded that alleged violations of plaintiff's statutory rights were sufficient to satisfy the injury-in-fact requirement of Article III, and plaintiff had adequately pled causation and redressability. Accordingly, the court reversed and remanded the district court's dismissal, concluding that plaintiff adequately alleged Article III standing.
Court Description: Standing / Fair Credit Reporting Act. The panel reversed the district court’s dismissal, based on lack of Article III standing, of an action alleging willful violations of the Fair Credit Reporting Act. The panel held that the individual plaintiff had Article III standing to sue a website’s operator under the Fair Credit Reporting Act for publishing inaccurate personal information about himself. The panel also held that law of the case did not limit the district court in its final order, and it was free to reconsider its own prior ruling on standing, where the district court had neither been divested of jurisdiction nor submitted this case to the jury.
The court issued a subsequent related opinion or order on August 15, 2017.