Spokeo, Inc. v. Robins

Supreme Court of the United States · 2016 · Federal Courts

Reporter Citation Pending

Updated August 1, 2026

Federal Courtsconcrete injurystatutory violationsArticle IIIstandinginjury in factparticularized injurystatutory right

Facts

Spokeo operates a website that searches databases and provides personal information about individuals. Spokeo generated a profile about Robins that allegedly contained inaccurate information, including that he was married, had children, was in his 50's, had a job, was relatively affluent, and held a graduate degree. Robins sued under the FCRA, alleging that Spokeo, as a consumer reporting agency, willfully failed to comply with statutory requirements including the duty to follow reasonable procedures to assure maximum possible accuracy. The Ninth Circuit held that Robins had alleged injury in fact because the asserted statutory violations affected his own individualized interests.

Issue

Whether a plaintiff satisfies Article III's injury-in-fact requirement by alleging that a defendant violated his statutory rights under the FCRA and that his personal interests were individually affected, without separately addressing whether the alleged injury was concrete. More specifically, whether a bare procedural violation of a statute is enough to establish standing.

Rule

To establish Article III standing, a plaintiff must show an injury in fact that is both particularized and concrete, actual or imminent, fairly traceable to the defendant, and likely redressable by a favorable decision. A concrete injury need not be tangible, and the violation of a statutory procedural right can in some circumstances constitute injury in fact, but a plaintiff does not automatically satisfy Article III whenever a statute grants a right to sue; a bare procedural violation divorced from any concrete harm does not suffice.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Nora Patel of Phoenix, Arizona sued Desert Ledger Data, a fictional consumer-reporting company, in federal court under a federal accuracy statute. She alleged the company published a file about her containing an incorrect apartment number, and she sought statutory damages solely because the file concerned her personally.

Which is the best analysis of Nora's standing at the pleading stage?

Explanation. Article III requires an injury in fact that is both particularized and concrete. A harm is particularized when it affects the plaintiff in a personal and individual way, but that alone is insufficient. The majority explained that some inaccuracies—like a trivial incorrect item that causes no harm or material risk of harm—may not satisfy concreteness. So the fact that the file is hers does not automatically establish standing. (Derived from Spokeo, Inc. v. Robins (n.d.).)