Eleventh Circuit Holds No Article III Standing in TCPA Case Involving Ringless Voice Mail Message
By EsqSocial Corporation 18/12/20
Last year, the Eleventh Circuit held in Salcedo v. Hanna, 936 F.3d 1162 (11th Cir. 2019) that a plaintiff did not have Article III standing to sue for a violation of the TCPA based on receipt of a single text message. The Eleventh Circuit has now extended its reasoning in Salcedo in holding that a plaintiff does not suffer concrete injury through receipt of a single ringless voice mail message. Grigorian v. FCA US LLC, No. 19-15026, 2020 WL 7238392 (11th Cir. Dec. 9, 2020)....
By: Womble Bond Dickinson