The Seventh Circuit rejected emotional distress and other
intangible injuries as a basis for Article III standing in a class
action seeking statutory damages under the Fair Debt Collection
Practices Act (FDCPA). In Pierre v. Midland Credit Management,
Inc., Nos. 19-2993 & 19-3109, 2022 WL 986441 (7th Cir.
Apr. 1, 2022), relying on the recent Supreme Court decision in
TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021), the
Seventh Circuit vacated and remanded with instructions to dismiss
for lack of subject-matter jurisdiction. It is just the latest in a
growing number of appellate court decisions addressing Article III
standing in class actions based on statutory damages claims.
Factual and Procedural Background
