Le v. Medtronic, Inc.

Background

Lan Le brought a proposed class action against Medtronic, Inc., Covidien, L.P., and Does 1-50. Le alleged that he had been employed by the defendants and, as part of the employment application process, signed a "Disclosure Regarding Background Reports" and an "Authorization to Obtain Background Check Reports."

Le asserted four claims: two under the Fair Credit Reporting Act (FCRA), alleging improper disclosure and authorization procedures for consumer reports; one under California’s Investigative Consumer Reporting Agencies Act; and one under California’s Consumer Credit Reporting Agencies Act. The case was initially filed in the United States District Court for the Southern District of California. That court transferred the case to the District of Minnesota and denied the defendants’ earlier motion to dismiss as moot. The defendants then renewed their motion under Federal Rule of Civil Procedure 12(b)(6), which addresses failure to state a claim for relief.

Meet-and-Confer Issue

Le argued that the defendants had not satisfied District of Minnesota Local Rule 7.1(a), which generally requires the parties to make a good-faith effort to resolve motion issues before filing a motion. The court found that the defendants had filed the required statement and had discussed the same arguments with Le before the transfer. Although the defendants did not conduct a renewed meet-and-confer after the transfer, the court held that this did not justify denying the motion.

Standing and Jurisdiction

The defendants argued that Le lacked Article III standing, meaning a sufficient injury required for a federal court to exercise jurisdiction. The court explained that standing requires an injury in fact, a connection between the injury and the defendant’s conduct, and a likelihood that a favorable decision would remedy the injury.

Le alleged that he and the proposed class members were confused about their rights under the FCRA. The court held that this was a bare assertion unsupported by specific facts explaining how the disclosure caused confusion. Le also alleged an invasion of privacy based on the defendants’ obtaining consumer reports without proper authorization. The court held that Le could not establish that injury because he had signed the authorization. The court further stated that parties generally are bound by contracts they sign even if they do not read or understand the terms, absent circumstances such as fraud, overreaching, or excusable neglect.

The court concluded that Le had not alleged a concrete injury sufficient to establish standing. Because standing is required for federal subject-matter jurisdiction, the court held that it lacked jurisdiction over the claims and did not decide whether the alleged disclosure and authorization practices violated the FCRA or California law.

Disposition

The court granted the defendants’ motion to dismiss. It dismissed Le’s amended complaint without prejudice for lack of subject-matter jurisdiction and ordered that judgment be entered. Judge Wilhelmina M. Wright signed the order.