Chicago-based litigators Sarah Zielinski and Jason Chrestionson bring us an update on the issue of individualized inquiry and Article III’s injury-in-fact requirement under the Supreme Court’s landmark decision in Spokeo, Inc. v. Robins.

Earlier this year, the Northern District of Illinois declined to certify a Telephone Consumer Protection Act (TCPA) class action even though the key issue in the case—whether class members had provided prior express written consent to receive prerecorded telemarketing calls—appeared to be a common question.  In Legg. v. PTZ Insurance Agency, Ltd., it seemed apparent “that none of the proposed class members” provided prior express … Continue Reading