Limon v. Circle K Stores
The court held that, under California law, a plaintiff may not maintain a Fair Credit Reporting Act claim without demonstrating a concrete, adverse injury, and therefore Ernesto Limon's alleged informational injury-simply receiving a consumer-report disclosure in the wrong format-failed to satisfy the standing requirement, leading the court to affirm the trial court's dismissal of his action.
Date Filed: October 25, 2022
Case Name: Limon v. Circle K Stores
Case Number: F082289
Court: California Court of Appeal, Fifth Appellate District
The court decides whether a plaintiff can maintain a Fair Credit Reporting Act claim without showing a concrete injury. It holds that Ernesto\u202fLimon lacks standing because his alleged “informational injury” – the mere receipt of a consumer‑report disclosure in the wrong format – does not constitute a cognizable harm under California law, and therefore the trial court’s dismissal of the action is affirmed. This ruling clarifies that, for any California action (including probate‑related disputes that invoke consumer‑report statutes), plaintiffs must allege a concrete, adverse injury to satisfy the standing requirement.
This case summary was prepared for educational purposes. For the authoritative version, please refer to the full opinion or the official California Courts website.