In Huff v. Telecheckservices,inc, No. 18-5438, 2019 U.S. App. LEXIS 13367 (6th Cir. May 3, 2019), the Court of Appeal for the Sixth Circuit found that an FCRA plaintiff had no no Art. III standing.
This case deals with a fading technology (checks) and an evergreen imperative (Article III standing). When a customer buys something with a check, merchants often consult a check verification company to determine whether to accept the check. Invoking his rights under the Fair Credit Reporting Act, James Huff requested a copy of his file from [*2] a check verification company called TeleCheck. The report omitted that his driver’s license was linked to six different bank accounts and omitted two transactions that occurred on those accounts. Huff filed this lawsuit under the Act. Because Huff has not shown that the incomplete report injured him in any way, we affirm the district court’s dismissal of his case for lack of standing.