Griffin v. Dept. of Lab. Fed. Credit Union, 18-1312, 2019 WL 80704 (4th Cir. Jan. 3, 2019), decided earlier today, the Fourth Circuit gave the defendant credit union a victory that on its face is meaningful only for credit unions and other membership organizations. However, although its conclusive denial of standing for the plaintiff was stated in the narrowest terms, the reasoning implies a view of standing with much broader implications. Standing requires that a plaintiff have have suffered a past injury that was concrete and particularized, and face the imminent threat of future harm. The Court concluded Griffen met none of these requirements because he was ineligible as a matter of law to use the services of the defendant credit union. More


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