Askins v. CRST Expedited, Inc.

Summary

The California Court of Appeal, First Appellate District, Division Three, held that the Fair Credit Reporting Act does not require a plaintiff litigating in California state court to prove concrete or actual injury to establish standing for a statutory violation. The court concluded that the FCRA authorizes statutory damages for willful violations even absent proof of harm and that the statutory violation itself supplies a sufficient interest to maintain the action. The court reversed the trial court’s order decertifying the class and declined to follow Limon v. Circle K Stores Inc.

Holdings

1. The FCRA does not require a California plaintiff to demonstrate concrete injury beyond the alleged violation of FCRA rights to establish standing in California state court. The statutory violation itself supplies the sufficient interest necessary to maintain the action.
2. A consumer may recover statutory damages of $100 to $1,000 for a willful FCRA violation even without proof of actual damages, measurable loss, or consequential harm.

Questions Presented

1. Whether California standing law requires a plaintiff asserting a FCRA claim in California state court to prove concrete or actual injury beyond the alleged statutory violation.
2. Whether a willful violation of 15 U.S.C. section 1681n permits recovery of statutory damages without proof of actual damages or other concrete harm.
3. Whether the trial court abused its discretion by decertifying the class based on the plaintiff's failure to allege concrete injury.

Disposition

reversed_and_remanded