In Pierre v. Midland Credit Management, Inc., — F.4th —, 2022 WL 986441 (7th Cir. Apr. 1, 2022), the Seventh Circuit affirmed the dismissal of a claim under the Fair Debt Collection Practices Act (“FDCPA”), finding that the plaintiff and the putative class which she represented suffered no concrete injury and therefore lacked Article III standing under the framework set out in Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) and TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021). Plaintiff Renetrice Pierre filed a class action lawsuit, seeking to represent a class of Illinois ...
Following the Supreme Court’s decision in Spokeo, Inc. v. Robins, 578 U.S. 330 (2016), federal courts have continued to examine what is an injury in fact under the Fair Credit Reporting Act (“FCRA”). On April 4, 2022, the Eighth Circuit provided instructions on remand to dismiss a FCRA class action due to lack of standing in Schumacher v. SC Data Ctr., Inc., --- F.4th ----, 2022 WL 997742 (8th Cir. Apr. 4, 2022). Ria Schumacher applied for a position at SC Data and during the application process answered “no” to a question asking if she had been convicted of a felony. In connection ...