Law360 Byline Discusses Eleventh Circuit Ruling on Article III Standing Requirements

September 29, 2022

Hinshaw attorneys David Schultz, Justin Penn, and Louis Manetti recently authored a Law360 Expert Analysis article that discusses the Eleventh Circuit's en banc decision in Hunstein v. Preferred Collection and Management Services Inc.. Hunstein held that a debt collector's use of a mail vendor did not create a concrete injury necessary to give the plaintiff Article III standing to sue in federal court. The article is titled, "11th Circ. Ruling Emphasizes Article III Struggles After Spokeo."

The authors note that this case illustrates how federal courts have increasingly been asked to "grapple with the proper method to analyze whether a plaintiff has suffered a concrete injury to satisfy Article III standing requirements in the wake of the U.S. Supreme Court's 2016 decision in Spokeo Inc. v. Robins."

They examine the details of the Hunstein decision, and conclude, "[a]s this sharply divided Eleventh Circuit ruling demonstrates, courts likely will continue to struggle through the Article III analysis for intangible harms."

"11th Circ. Ruling Emphasizes Article III Struggles After Spokeo" was published by Law360 on September 27, 2022

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