New York Federal Court Holds Plaintiffs Lacked Article III Standing in Putative Class Action Alleging Violations for Failure to File Mortgage Satisfactions

The United States District Court for the Southern District of New York recently held that plaintiffs in a putative class action alleging violations of New York state statutes requiring mortgagees to file timely mortgage satisfactions do not have Article III in light of Spokeo, Inc. v. Robins, 136 S.Ct. 1540 (2016).