Urban Outfitters, Anthropologie Dodge Putative ZIP Code Class Action Under Spokeo

The Court of Appeals for the District of Columbia shot down a putative class action brought against Urban Outfitters, Inc., and Anthropologie, Inc., which had alleged that the companies violated D.C. consumer protection statutes by collecting customer ZIP code information during in-store checkout. The July 26 ruling remanded the suit for dismissal, and held that Plaintiffs failed to establish Article III standing under the Supreme Court's recent decision in Spokeo. The ruling highlights the continuing obstacles facing would-be class action plaintiffs under Spokeo.

Plaintiffs Whitney Hancock and Jamie White brought the action against the retailers for alleged violations of the District of Columbia's Use of Consumer Identification Information Act (the "Identification Act") and its Consumer Protection Procedures Act (the "Protection Act"). Specifically, Plaintiffs alleged that Defendants' request for ZIP codes at checkout violated the Identification Act's ban on