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Salcedo v. Hanna

John Salcedo brought a class action lawsuit against Alex Hanna and the Law Offices of Alex Hanna, PA, alleging that the defendants had violated the Telephone Consumer Protection Act (TCPA) by sending unconsented-to, auto-dialer text messages to Mr. Salcedo and other former clients of theirs. The defendants moved to dismiss for a lack of standing, among other things. After the district court denied the motion, the defendants appealed to the U.S. Court of Appeals for the Eleventh Circuit. Public Citizen represented Mr. Salcedo on appeal. The Eleventh Circuit reversed the district court and held that Mr. Salcedo lacked standing. Although stating that the standing question was “close,” the court held that Mr. Salcedo had the defendants’ violation of the TCPA had not caused a concrete injury. The court also denied our petition for rehearing en banc.