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Debt Collector’s Validation of Debt Did Not Violate the FDCPA as a Matter of Law

On February 2, Judge Robert T. Dawson, in the Western District of Arkansas, granted a defendant debt collector’s motion for summary judgment. The court determined Monterey Financial Service LLC’s responses to plaintiff Kyle...more

Acting CFPB Director Dave Uejio to Heighten Supervisory and Enforcement Actions, Including Resuming Military Lending Act...

In a statement recently disseminated to all Consumer Financial Protection Bureau (CFPB) personnel, Acting Director Dave Uejio set forth new priorities for the CFPB’s Supervision, Enforcement, and Fair Lending Division (SEFL),...more

District Court Dismisses FDCPA Case Because Plaintiff Could Not Prove Sufficient Actual Injury

In Giannini v. Fin. Recovery Servs., Judge Ellis of the District Court for the Northern District of Illinois dismissed a case alleging the defendant violated the Fair Debt Collection Practices Act by “fail[ing] to include...more

Seventh Circuit Finds Plaintiff Lacks Standing to Bring FDCPA Based on Collection Letter

In Smith v. GC Servs. Ltd. P’ship, No. 19-3494 (7th Cir. Jan. 21, 2021), the Seventh Circuit affirmed a decision by the Southern District of Indiana finding that the plaintiff had not suffered any concrete injury and...more

Another Circuit Split: Eleventh Circuit Holds that Administrative Feasibility is a Factor for Courts to Consider on Class...

In Cherry v. Dometic Corp., the Eleventh Circuit Court of Appeals held that, when addressing a motion for class certification, courts may consider whether the named plaintiff has demonstrated an administratively feasible...more

Debt Collection and Estates: District of New Jersey Court Grants in Part and Denies in Part Defendant’s Motion to Dismiss FDCPA...

In Rock v. Greenspoon Marder LLP, Judge Vazquez of the District Court for the District of New Jersey granted the defendant’s motion to dismiss the plaintiff’s Fair Debt Collection Practices Act (FDCPA) claim in part and...more

District Court Grants Plaintiff’s Motion to Certify Class in Part, Refusing to Credit Testimony Regarding Unwritten Consent...

In Vandenberg & Sons Furniture, Inc. v. Alliance Funding Grp., Judge Quist of the District Court for the Western District of Michigan granted in part and denied in part the plaintiff’s motion for class certification arising...more

Reasonable Procedures and The Bona Fide Error Defense: District Court for the Southern District of Indiana Grants Summary Judgment...

In Ewing v. Med-1 Solutions, Judge Sweeney II of the District Court for the Southern District of Indiana granted summary judgment for the defendant, regarding the plaintiff’s allegation that the defendant violated the Fair...more

Washington State AG Pushes for Increased Penalties for Consumer Violations

Washington State Attorney General Bob Ferguson recently announced priorities for his 2021 legislative agenda. These priorities include public safety and criminal justice reform, tribal treaty rights, and protecting consumers....more

Service Fee Language in Debt Collection Letters: District Court for the Eastern District of California Grants Defendants’ Motion...

In Martinez v. Integrated Capital Recovery, LLC, Judge Ishii of the District Court for the Eastern District of California granted the Defendants’ motion to dismiss two Fair Debt Collection Protection Act (“FDCPA”) claims...more

Summary Judgment & Shifting the Burden of Proof: Court Grants Summary Judgment for Plaintiff and Denies Summary Judgment for...

In Russell v. Law, Judge Van Bokkelen, of the United States District Court for the Northern District of Indiana, granted summary judgment, in part, to Russell Friend (“Plaintiff”)– alleging Taylor Law, PLLC (“Defendant”)...more

Ambiguity in Debt Collection Letters: The United States District Court for the Middle District of North Carolina Denies Motion to...

In Golden v. Benjamin, Judge Schroeder, of the United States District Court for the Middle District of North Carolina, denied Higgins Benjamin, PLCC’s (“Higgins”) motion to dismiss a class action claim brought by Mark and...more

Storytelling & Professional Plaintiffs: The District Court for the Northern District of Texas Denies Class Certification in TCPA...

In Hirsch v. USHealth Advisors, LLC, Judge Pittman, of the United States District Court for the Northern District of Texas, denied Aaron Hirsch’s (“Plaintiff”) Motion for Class Certification, which was based on allegations...more

District Court Finds Calls to Cell Phones Do not Violate the TCPA’s Prohibition Against Telephone Solicitations to Residential...

In an Order issued December 16, 2020, the Eastern District of Texas adopted the Report and Recommendation of United States Magistrate Judge Kimberly C. Priest Johnson finding that calls placed to a cellular telephone do not...more

The CFPB Revises Reg. Z’s Qualified Mortgage Loan Criteria in Anticipation of the GSE Patch’s Expiration

In anticipation of the “GSE patch” expiring, the Consumer Financial Protection Bureau (“CFPB”) issued several final rules in 2020 to amend Regulation Z (“Reg. Z”). Concerns have existed that the expiration of the GSE patch...more

One Ringless Voicemail: On Appeal, Eleventh Circuit Affirms District Court Holding on Article III Standing in TCPA Case

On appeal in Grigorian v. FCA US LLC, the Eleventh Circuit affirmed the holding of Judge Cooke, of the United States District Court for the Southern District of Florida, that Mariam Grigorian (“Mariam”), Plaintiff and...more

Context Matters: Court Grants Summary Judgment for Defendant and Emphasizes that Entire Tradeline Must be Analyzed in FCRA Claims

In Ellis v. Warehouse Home Furnishings Distribs., Judge Catherine M. Salinas, of the United States District Court for the Northern District of Georgia, granted summary judgment for Warehouse Home Furnishings Distributors,...more

Separation of Powers & Severability: On Remand, the Ninth Circuit Court of Appeals Holds CFPB Director Ratification of Civil...

On remand from the United States Supreme Court, the United States Court of Appeals for the Ninth Circuit, in Consumer Fin. Prot. Bureau v. Seila Law LLC, reaffirmed a District Court grant of a petition by the Consumer...more

Big News for Background Screening: New Appellate Ruling Says FCRA Permits Reporting Unmatched Criminal Records

Addressing a recurring issue bedeviling the background screening industry, the U.S. Court of Appeals for the Eleventh Circuit confirmed on December 4 that it is not inaccurate for a consumer reporting agency (CRA) to report a...more

Relying on Commonly Used Name, Without More, Does Not Violate the FDCPA

On December 4, Judge William M. Conley, in the Western District of Wisconsin, granted a defendant debt collector’s motion to dismiss without prejudice. The Court determined that while the plaintiff Mikayla Fellenz has...more

Supreme Court Answers the Call on the Definition of an Autodialer

The U.S. Supreme Court heard oral argument today in Duguid v. Facebook to decide, once and for all, whether an automatic telephone dialing system (ATDS), as defined in the Telephone Consumer Protection Act (TCPA), requires a...more

District Court Reduces Request for Attorneys’ Fees in FDCPA Suit by More than Half in Response to Litigated Offer of Judgment

In Gould v. Monarch Recovery Mgmt., No. 18-C-1282 (E.D. Wis. Nov. 10, 2020), the Plaintiff’s counsel sought $57,073.37 in attorneys’ fees after accepting an offer of judgment as to claims under the Fair Debt Collections...more

District Court Finds Plaintiff Lacks Standing to Bring FDCPA Suit After He Testified That He had Not Read the Collection Letter at...

In Truckenbrodt v. CBE Grp., Inc., No. 2:19-cv-2870 (ERK) (SMG), (E.D.N.Y. Oct. 21, 2020) the court dismissed a suit brought under the Fair Debt Collections Practices Act (“FDCPA”) after the plaintiff conceded that he had not...more

Failure to Itemize Debt Is Not A Violation of the FDCPA

In Vogel v. McCarthy, Burgess & Wolff, the United States District Court for the Northern District of Illinois (the “Court”) granted summary judgment to a debt collector on a debtor’s claim that failure to itemize debt in a...more

10/28/2020  /  Debt , Debt Collection , Debt Collectors , FDCPA

Eleventh Circuit Rejects Incentive and Award to Class Representative in TCPA Class Action

In Johnson v. NPAS Sols., LLC, No. 18-12344 (11th Cir. Sep. 17, 2020), the Eleventh Circuit (the “Court”) found a series of errors in an order entered by the Southern District of Florida approving the settlement of a class...more

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