BIPA Cases: 7th Circuit Rules Change to Illinois Law’s Damages Provision Retroactively Limits Defendant Exposure

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Why it matters

On April 1, 2026, the U.S. Court of Appeals for the Seventh Circuit ruled in Clay v. Union Pacific Railroad Co. that a 2024 amendment to Illinois' Biometric Information Privacy Act (BIPA)—limiting statutory damages to one recovery per person per collection method—applies retroactively to pending cases, rejecting "per-scan" damages that could yield billions.[1][2][3][4]

The core event consolidated three interlocutory appeals (Clay, Gregg, and another unnamed case) where defendants argued the amendment capped damages under BIPA Section 20, while plaintiffs sought massive per-violation awards (e.g., $7.5 million individually, billions in class claims).[3][4][6][10] Key parties include plaintiffs (e.g., Clay), defendants Union Pacific Railroad Co. and others, the Illinois General Assembly (enactor of Public Act 103-0769, effective August 2, 2024), and Chief Judge Michael Brennan authoring the unanimous opinion.[1][5][6][12] Lower district courts had split, some deeming it substantive (prospective only), others clarifying it retroactively.[6][10][15]

Context stems from BIPA's 2008 enactment regulating biometric data (e.g., fingerprints, facial scans) with $1,000–$5,000 liquidated damages per violation; the 2023 Illinois Supreme Court Cothron decision affirmed per-scan accrual, prompting 2024 amendment to cap at "at most, one recovery" per method without altering Section 15 liability.[7][10][12][13] The Seventh Circuit classified it as procedural/remedial (amending damages only), applying retroactively under Illinois law where pending cases conform to current statutes absent substantive change.[1][3][8][11]

Newsworthy for drastically cutting defendants' exposure in hundreds of pending BIPA suits (overturning district consensus), reinforcing judicial discretion in damages, and potentially reshaping settlements/jurisdiction amid "astronomical" pre-amendment risks.[2][4][9][10][12] Issued just before April 12, 2026, it accelerates resolutions for businesses.[3][14]

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