Ria Schumacher v. SC Data Center, Inc.
Opinion
*1105 After the parties reached a tentative settlement in this purported class action, SC Data Center, Inc., moved to dismiss the case on the ground that the class representative, Ria Schumacher, lacked standing. However, the district court enforced the settlement between the parties without deciding the standing issue. SC Data Center appeals, arguing the district court erred by not deciding standing first. We agree, vacate the district court's approval of the settlement agreement, and remand the case.
In February 2016, Schumacher filed a purported class action in the Circuit Court of Cole County, Missouri, alleging that SC Data Center committed three violations of the Fair Credit Reporting Act ("FCRA"),
Subsequently, in July 2016, SC Data Center moved to dismiss this action for lack of standing. The district court denied the motion, concluding that "Schumacher's standing to bring the FCRA claims underlying this settlement is irrelevant to whether she has standing to enforce the parties' settlement agreement."
The district court ordered the parties to submit their settlement agreement for approval under Fed. R. Civ. P. 23(e), and they complied. The district court approved the settlement, and SC Data Center timely appealed the decision.
We agree with SC Data Center that the district court erred by not assessing standing before enforcing the settlement agreement. "Article III standing must be decided first by the court and presents a question of justiciability; if it is lacking, a federal court has no subject-matter jurisdiction over the claim."
Miller v. Redwood Toxicology Lab., Inc.
,
Schumacher argues that the district court did not need to reassess standing after
Spokeo
because SC Data Center cannot escape the settlement agreement based on a change in the law. Specifically, she relies on
Ehrheart v. Verizon Wireless
,
Her argument is not persuasive here because
Spokeo
, even if it was a catalyst for SC Data Center's motion to dismiss, was not a change in the substantive law bearing on Schumacher's claim that would have "altered the settlement calculus."
Because there is no finding in the record regarding whether Schumacher had standing to pursue her claims, we vacate the district court's approval of the settlement agreement and remand the case for a decision on whether Schumacher has standing. We express no view on whether the Seventh Circuit's opinion on FCRA standing or one of the competing approaches in other circuits is best applied to the facts of this case.
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Reference
- Full Case Name
- Ria SCHUMACHER, Individually and on Behalf of All Others, Plaintiff - Appellee v. SC DATA CENTER, INC., Doing Business as Colony Brands, Inc., Defendant - Appellant
- Cited By
- 15 cases
- Status
- Published