Truth in Lending: 11.2.4.4 Pleading to Show Standing
The Supreme Court summarized the crux of its Ramirez decision as “No concrete harm, no standing.”205 While the Court did not provide an equally pithy explanation of what constitutes concrete harm, plaintiffs should still strive to explain their injury as explicitly as possible to survive pro forma motions to dismiss. Of course, surviving a motion to dismiss is not the same as prevailing on a motion for summary judgment.