The 9th Circuit recently held that individual class members must satisfy Article III’s standing requirements in order to recover individual monetary damages. Class members who are a part of Ramirez v. TransUnion LLC who experienced no injury-in-fact traceable to the alleged statutory violation or challenged conduct must be excluded from any class damages award. The underlying litigation arises from a credit report by defendant TransUnion that identified plaintiff Ramirez’s name as matching two names on the U.S. Department of Treasury’s Office of Foreign Asset Control (OFAC) Database. Ramirez filed the putative class action claiming that Transunion’s OFAC alert practices violated various provisions of the Fair Credit Reporting Act (FCRA).
