The Northern District of California dismissed a Fair
Credit Reporting Act case against Lyft upon finding that
plaintiff lacked Article III standing based on the Supreme
Court's decision in Spokeo, Inc. v.
Robins, 136 S. Ct. 1540 (2016). The court found that
plaintiff did not suffer any actual injury, or a real threat of
such injury, as a result of Lyft's alleged FCRA violations. The
court's ruling was consistent with several recent district
courts' decisions based on similar facts, and expressly
rejected the Eleventh Circuit's broad reading of
Spokeo on the issue of "informational"
injury.
Plaintiff sued Lyft on behalf of himself and a putative class
who signed an employment application that contained
"extraneous information" embedded with certain FCRA
disclosures and failed to advise the applicant of his right to
request a summary of his FCRA rights. As a result, according to
plaintiff, Lyft procured his credit and background report in
violation of the FCRA
