FDCPA Violation

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7^th Circuit Court of Appeals

Case Name: Quentin Crabtree v. Experian Information Solutions, Inc.,

Case No.: 18-3416; 18-3405

Officials: ROVNER, SCUDDER, and ST. EVE, Circuit Judges.

Focus: FDCPA Violation

We know from the Supreme Court’s decision in Spokeo, Inc. v. Robins that a plaintiff claiming a statutory violation must allege a concrete and particularized injury for Article III standing. Recent years have shown that this principle is often easier to observe than to apply. The claim in this appeal falls on the easier side. Quentin Crabtree filed this suit against Experian for what he contends was an unauthorized release of his credit information under the Fair Credit Reporting Act. Experian responded by going on the offensive by itself bringing a FCRA counterclaim against Crabtree. The district court dismissed Crabtree’s claim because any injury was exceedingly remote and speculative. We agree. We further conclude that Experian’s counterclaim likewise fails for lack of standing and therefore affirm across the board.

Affirmed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.