The Eleventh Circuit last month issued a significant class action opinion in Cordoba v. DirectTV, LLC, vacating a class certified in a TCPA class action and remanding the case.    The issue “I told you never to call me here”: Eleventh Circuit Decertifies TCPA Class Containing Absent Class Members Without Article III Standingunderlying the court’s decision was whether large parts of the class as certified had standing.  Because the plaintiff did not establish that common

It’s None of Your Business: Sixth Circuit Says Arizona Lacks Article III Standing to Intervene to Challenge a Class SettlementDoes a state, whose citizens are among the absent class members in a class action settlement, have Article III standing to challenge the supposed unfairness of the settlement? In Chapman v. Tristar Products, Inc., the Sixth Circuit said no.

The Trial Court’s Decision

Chapman involved a product liability class action against the manufacturer of

One Spam Text Does Not Confer Standing in the Eleventh CircuitOne unwanted text message does not confer standing in federal court in the Eleventh Circuit — so holds the court in Salcedo v. Hanna. The case confirms that one text message is qualitatively, and jurisprudentially, different from the kind of intrusions that give rise to an Article III injury-in-fact.

The plaintiff in Salcedo claimed