The Eastern District of Pennsylvania confirmed that the plaintiff in Davis v. C&D Sec. Mgmt. lacks Article III standing to state a claim for violation of the Fair Credit Reporting Act (FCRA) premised solely on the failure to receive a copy of the background report and the statute’s procedurally-required summary of rights. The plaintiff applied for employment and, after being denied twice, brought suit on behalf of a putative class, claiming that the business failed to provide her with notice, a copy of her report and a summary of her rights under the FCRA. The court held that Davis lacked an injury-in-fact and that, because Davis failed to establish her own standing, she may not seek relief on behalf of the putative class.
