Consumer Class Standing Faces Uncertainty In 11th Circ.
Law360 (September 17, 2019, 5:08 PM EDT) -- A recent opinion from the U.S. Court of Appeals for the Eleventh Circuit could transform statutory consumer protection class actions in the court's jurisdiction. In Salcedo v. Hanna, the Eleventh Circuit considered an interlocutory appeal of a putative class action brought under the Telephone Consumer Protection Act and held that receipt of a single unsolicited text message sent in violation of the TCPA does not, in and of itself, create the requisite Article III standing for a plaintiff to bring a case in federal court.
In so holding, the Eleventh Circuit made clear that a court’s Article III standing inquiry in the...
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