On March 30, 2021, the United States Supreme Court heard oral argument in Transunion LLC v. Ramirez, No. 20-297, a case that could have far-reaching implications on absent class member standing, particularly where the injuries of these absent class members would be impossible or difficult to establish.  The Court agreed to address whether Article III or Rule 23 permits a damages class action where the vast majority of the class suffered no actual injury, let alone an injury like what the class representative suffered.

Continue Reading Will No-Injury Class Actions Have Any Leg to Stand on? U.S. Supreme Court Hears Argument in TransUnion v. Ramirez

In Uzuegbnam v. Preczewski, the Supreme Court held that the award of nominal damages is sufficient to redress a past injury, satisfying Article III’s redressability requirement.  While at first blush, the opinion may appear to lessen the burden on any plaintiff in satisfying Article III standing, the more likely outcome is that the holding

TCPA class actions based on the receipt of unsolicited text messages have grown more common in recent years.  However, the Eleventh Circuit’s decision in Salcedo v. Hanna, may upend that trend by holding that a single unsolicited text message did not generate the harm necessary to satisfy Article III standing to sustain a Telephone Consumer