In the opening installment of this two-part article on the U.S. Supreme Court’s continuing evolution of standing, we set forth the doctrine’s foundational maxims, including Spokeo v. Robins, and then turned to the first of two fresh landmarks, California v. Texas. Today we analyze TransUnion v. Ramirez, 594 U.S. ___ (No. 20-297) (June 25, 2021), the second of these newest precedents, and the one some might argue (with good reason) is the more significant of the duo.

Law Abiding Citizen

TransUnion’s facts relate a rather pedestrian set of circumstances. Sergio Ramirez and his wife decided to purchase a new car from a Nissan dealership near their California home. As a routine part of the sale, the dealership requisitioned a credit report from TransUnion, one of the “Big Three” credit reporting agencies in the United States. The agency’s printout linked Ramirez to the watch list of terrorists, drug traffickers, and serious criminals maintained by the Treasury Department’s Office of Foreign Asset Control (OFAC). Forced to complete the purchase in his spouse’s name, Ramirez subsequently demanded an explanation from TransUnion.

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