Ashley B. Guffey of King & Spalding LLP writes:
On February 11, 2015, the U.S. District Court for the Southern District of Texas held that a plaintiff lacked standing to pursue claims for alleged violations of the Fair Credit Reporting Act, 15 U.S.C. § 1681 et seq. (“FCRA”) against St. Joseph Services Corporation d/b/a St. Joseph Health System, and St. Joseph Regional Health Center (collectively, “St. Joseph”). In dismissing a putative class action, the court found that the heightened risk of future identify theft or fraud posed by a data breach did not confer Article III standing on persons whose information may have been accessed. The District Court held that plaintiff could not establish Article III standing because she had not suffered an injury, actual or imminent, that was traceable to St. Joseph’s conduct.
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