Jurisdiction -- 2008



Sprint Communications Co. v. APCC Services, Inc.   (U.S. Supreme Court)

Whether assignment of claims confers standing on assignee

Cases in federal court may only be brought by persons who have suffered an actual injury. But may an injured person sell his or her constitutional standing to another person, so that that person many file suit based on a contractual right?

In this case, the D.C. Circuit ruled that intermediaries under contract with payphone service providers may bring suit on their behalf against a telecommunications carrier that owed compensation to the payphone service providers. The Supreme Court agreed, 5 to 4. At issue was whether the assignment of the claim to the intermediaries, who themselves have no personal stake in the case other than their right to litigate it on behalf of others, is sufficient to confer standing. The defendants argued that the intermediaries had no real stake in the case because their contract provides that any proceeds would go straight to the payphone companies.

The Court ruled that assignees of legal claims have for centuries been able to sue on behalf of those who assigned their legal rights to them. Because the injury will be redressed by paying the assignee of the legal claim, it doesn't matter what the assignee does with the award. He may give it back to the original claim holder and receive a fee for his service without undermining his standing in the litigation. This decision will make it easier to aggregate small claims for purposes of litigation.