No standing to challenge delayed release of title, Eighth Circuit holds

Under Missouri law, lienholders must release their liens within 5 days after payment in full of any moneys owed. According to the plaintiff in a putative class action, Santander Consumer violates this law by waiting fifteen days to send the title after a borrower pays off a car loan.

After Santander removed the case, a federal district court granted summary judgment to Santander on the merits. On appeal, the Eighth Circuit vacated that judgment, with instructions to remand to state court.  The Eighth Circuit held that the delay in releasing the title was not itself an Article III injury under Transunion, rejecting the argument that the harm caused was analogous to that recognizes at common law.

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