SuperValu Inc. and New Albertsons Inc. won’t have to face a class action over a 2014 data breach at 1,000 stores, the Eighth Circuit affirmed May 31.

One fraudulent credit card charge and the risk of future identify theft aren’t enough to create standing to sue under Illinois law, Judge Jane Kelly wrote for the U.S. Court of Appeals for the Eighth Circuit.

Courts are grappling with whether customers have standing to sue after a data breach. In general, consumers have struggled to convince courts they were actually harmed.

Two cyberattacks allowed hackers to steal customers’ payment card numbers, expiration...