Case Explained: BETZAIDA SANTOS-PAGÁN MINERVA M. HERNÁNDEZ-UMPIERRE v. BAYAMON MEDICAL CENTER DOES 1 TO 10

Court: United States Court of Appeals for the First Circuit Filed: 2026-06-11 The First Circuit affirmed the district court’s dismissal of the plaintiff’s putative class action regarding a hospital data breach for lack of Article III standing. The court held that while the plaintiff sufficiently alleged an “injury in fact” by claiming actual misuse of her personally identifiable information (PII) through a fraudulent cellphone account, she failed to satisfy the “traceability” requirement. Under the standard of review applied de novo, the court determined that the complaint did not plausibly allege facts supporting a causal connection between the data breach and the fraud. Specifically, the opinion found no reasonable inference of a temporal link given the years-long gap between the 2019 breach and the discovery of the account in late 2023, nor did the plaintiff adequately allege that she had taken steps to secure her PII or that the specific data exposed in the breach was the type required to open the fraudulent account. Consequently, because the injury was not fairly traceable to the defendant’s conduct, the court lacked subject matter jurisdiction and the case was dismissed without prejudice to the underlying state law claims but with prejudice to the federal statutory claim. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.