Across the Street to State Court: Standing, Removal, and Post-TransUnion Risk
Legal Learning Webinar
Join us for a webinar on February 24, 2026 at 3:00 PM EST.
Since the U.S. Supreme Court’s 2021 decision in TransUnion LLC v. Ramirez, Article III standing has become a
powerful gatekeeper for consumer claims in federal court—especially in debt collection, credit reporting, and related statutory litigation. But what happens when a federal court says there’s no standing? Can plaintiffs simply pivot to state court, and if so, do state standing rules impose the same injury requirements—or a different threshold entirely?
This program examines how state courts approach standing in the wake of TransUnion, where the doctrines diverge, and what that means for case strategy. The panel will explore practical implications for pleading and motion practice, removal considerations, and how to evaluate risk when a claim may be non-viable in federal court but potentially viable in state court.
Attendees will learn:
• Identify key differences between Article III standing and common state-court standing frameworks.
• Evaluate when a “no standing” federal outcome may (or may not) translate to state court.
• Spot strategic considerations for removal, remand, and early dispositive motions.
Speakers: Lauren Burnette, Messer Strickler Burnette, Ltd.; Josh Dickinson, Spencer Fane LLP; Jeff Topor, Womble Bond Dickinson (US) LLP
CLE is Pending Final State Approval
After registering, you will receive a confirmation email containing information about joining the webinar.
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CLE Information
National Creditors Bar Association is a national provider of legal educational content. NCBA’s goal is to provide its members with as many opportunities as possible to earn Continuing Legal Education (CLE) credits. Some NCBA webinars state that they are pending approval. If a webinar is pending approval, it means that NCBA’s education staff is awaiting confirmation of approval for CLE credit from the accrediting body of a particular state; it should be noted that individual states have different response and approval rates. NCBA expects that the course will be approved for the credit amount and type listed, but approval is not guaranteed. An attorney can still take the course at their own discretion, though.
It is not uncommon for a course which is pending approval to not be approved until after the webinar has taken place. Once an official decision notice arrives from the state, NCBA will notify attorneys who have completed the course as soon as possible via email, and will re-issue any certificates of completion to reflect the updated state reporting numbers. However, it is recommended that attorneys do not view webinars that are pending approval close to their CLE deadline, as NCBA cannot guarantee that a course will be approved in time.
National Creditors Bar Association will seek MCLE accreditation, with the assistance of the ABA MCLE, for this webinar. NCBA will seek General CLE credit hours in 60-minute-hour states, and in 50-minute states, subject to each state’s approval and credit rounding rules. States typically decide whether a program qualifies for MCLE credit in their jurisdiction 4-8 weeks after the program application is submitted. For many live events, credit approval is not received prior to the program. A link for CLE requests will be provided to webinar attendees who have met the attendance and engagement requirements.