11th Circuit Court of Appeals Rejects Class Action Alleging Violation of Mortgage Satisfaction Recording Laws, Finding Injury-In-Fact Lacking Under Spokeo.
On Oct. 6, 2016, the U.S. Court of Appeals for the 11th Circuit decided Nicklaw v. CitiMortgage, Inc ., — F.3d –, 2016 WL 5845682, (11th Cir. 2016), holding that a class action plaintiff who alleged that CitiMortgage violated New York law by failing to timely record a satisfaction of mortgage, lacked Article III standing because he had suffered no concrete injury. Nicklaw is one of the 11th …