Highlights from this issue include: 

• Pro Se Civil Rights Class Actions. The Seventh Circuit affirmed that a pro se prisoner cannot adequately represent a class.
• Concrete Damages after TransUnion. The Fourth Circuit noted that under TransUnion LLC v. Ramirez, “[e]very class member must have Article standing” “for each claim that they press,” which required proof that the challenged conduct caused each of them a concrete harm, and that the class cannot rely on a “mere risk of future harm.”
• Telephone Consumer Protection Act (TCPA). The Third Circuit affirmed the denial of certification for a class that alleged violations of the TCPA because to determine whether any individual class member had provided consent would require individualized review and mini-trials.