A single unauthorized payment card transaction following data breaches at SuperValu Inc. stores created sufficient injury for a class complaint to proceed, a federal appeals court held Aug. 30 (In re SuperValu, Inc. Customer Data Sec. Breach Litig., 8th Cir., No. 16-2378, 8/30/17).

Reversing a lower court’s dismissal of the complaint, the U.S. Court of Appeals for the Eighth Circuit held that named plaintiff David Holmes’ assertion of actual injury gives him standing to sue for himself and on behalf of similarly situated potential class members.

The appeals court rejected SuperValu’s argument that Holmes had to allege that...