Jeep Drivers' Claims Come To A Screeching Halt: Hypothetical Hacking Threat Does Not Confer Article III Standing

On March 27, 2020, a five-year legal battle between three certified classes of Jeep Cherokee drivers and Fiat Chrysler came to a sudden end, when a federal judge in the Southern District of Illinois held that allegations that the vehicles were vulnerable to cyber-attacks did not give plaintiffs standing to sue under Article III of the Constitution.

U.S. District Judge Staci M. Yandle—who was assigned to the case in April 2019, after Judge Michael Reagan retired—did not take lightly her decision to grant defendants' motion to dismiss for lack of jurisdiction, given the lengthy history of the dispute. Discovery had been completed, experts had been retained, and several motions involving the same standing issues had already been resolved—in plaintiffs' favor. But, as Judge Yandle explained, a federal court has "an independent obligation at each stage of the proceedings" to ensure that it has subject matter jurisdiction over the litigation. Ultimately, defendants'