Summary
The Supreme Court held that the Ninth Circuit’s Article III standing analysis was incomplete because it addressed particularization but did not separately assess concreteness. The Court explained that a statutory violation does not automatically establish standing without a concrete injury, although the risk of real harm or violation of certain statutory procedural rights may suffice. The judgment was vacated and the case remanded for further proceedings.
Questions Presented
- Whether Robins adequately alleged an injury in fact sufficient to establish Article III standing for his FCRA claims.
- Whether an alleged violation of statutory procedures, without additional concrete harm, satisfies Article III's concreteness requirement.
- Whether the Ninth Circuit properly analyzed both the particularization and concreteness components of injury in fact.
Holdings
- An injury in fact must be both concrete and particularized, as well as actual or imminent; the Ninth Circuit's analysis was incomplete because it addressed particularization but not concreteness.
- Congress cannot eliminate Article III's requirement of a concrete injury merely by creating a statutory right and authorizing a private lawsuit to vindicate it.
- The Court did not decide whether Robins's alleged FCRA violations were sufficiently concrete; the Ninth Circuit must determine whether the particular procedural violations alleged entail a degree of risk sufficient to satisfy Article III.
Factual background
Spokeo operated a people-search website that gathered and disseminated personal information from numerous databases. Robins alleged that Spokeo's profile about him contained multiple inaccuracies, including information about his age, marital status, children, employment, education, wealth, and economic status. He alleged that the inaccurate information harmed or threatened his employment prospects.
Procedural history
Robins filed a putative federal class action alleging that Spokeo willfully violated the Fair Credit Reporting Act by disseminating inaccurate information about him. The Central District of California dismissed the complaint with prejudice for failure to plead injury in fact. The Ninth Circuit reversed, concluding that Robins adequately alleged injury in fact because Spokeo violated his statutory rights and his interests were individualized. The Supreme Court vacated and remanded because the Ninth Circuit considered particularization but failed to independently consider concreteness.