The Ninth Circuit follows the Second and Seventh Circuits in dismissing consumer class actions in which named plaintiff alleges no injury other than statutory damages.

Key Points:

..In Bassett v. ABM Parking Services, Inc., the Ninth Circuit applies Spokeo, Inc. v. Robins in holding that a named plaintiff must allege a sufficiently concrete injury.

..While Bassett addresses a claim brought under FACTA, the decision may have broader implications because plaintiffs claiming bare procedural violations of other consumer protection statutes, without more, will have similar difficulty establishing standing to sue.

..Companies should not view Bassett as amnesty for violating statutes that provide for statutory damages such as FACTA, and must remain vigilant in ensuring compliance with statutes.

..Bassett will likely present an obstacle to plaintiffs seeking class certification because whether or not a particular putative class member suffered a concrete Article III injury will result in highly individualized inquiries.