News & Analysis as of

Article III Debt Collectors Injury-in-Fact

Orrick, Herrington & Sutcliffe LLP

3rd Circuit finds appellant does not have FDCPA standing where only injury was confusion

On April 26, the U.S. Court of Appeals for the Third Circuit held that an appellant who sued a debt collector for allegedly violating the FDCPA did not have standing to bring her claim because she “failed to plead a concrete...more

Troutman Pepper

Florida State Court Dismisses Letter Vendor Claim for Lack of Standing

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In Scott v. Collecto, Inc., the plaintiff filed a complaint in state court alleging a violation of the Fair Debt Collection Practices Act (FDCPA) and common law negligence based on the defendant’s use of a letter vendor to...more

Tucker Arensberg, P.C.

Third Circuit: Consumer Does Not Have Standing to Raise FDCPA Challenge to Debt Collection Agency’s Disclosure of Private...

In Barclift v. Keystone Credit Services, LLC, the Philadelphia-based United States Court of Appeals for the Third Circuit determined that a Consumer did not have standing to sue under Fair Debt Collection Practices Act...more

Burr & Forman

Third Circuit Weighs in on Mailing Vendors in Debt Collection and Article III Standing

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The Third Circuit Court of Appeal recently weighed in on the burgeoning number of cases alleging that debt collector use of mailing vendors requires communication with a third party about consumer debt that violates the Fair...more

Troutman Pepper

Citing Recent Precedent, Third Circuit Finds Plaintiff Lacks Standing Based on Informational Injury Doctrine in FDCPA Class Action

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On November 22, the Third Circuit Court of Appeals issued a decision finding that the plaintiff lacked Article III standing in a putative class action brought under the Fair Debt Collection Practices Act (FDCPA)....more

Troutman Pepper

New Jersey Federal Court Dismisses FDCPA Claim Based on Alleged Failure to Obtain Proper License for Lack of Standing

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In Valentine v. Mullooly, Jeffrey, Rooney & Fylnn LLP the U.S. District Court for the District of New Jersey found that the plaintiff had not suffered an injury in fact and therefore lacked standing to assert a claim under...more

Ballard Spahr LLP

Tenth Circuit Dismisses FDCPA Claim for Lack of Standing Where Third-Party Mail Vendor Sent Collection Letters

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The U.S. Court of Appeals for the Tenth Circuit recently joined the Eleventh Circuit (and a growing majority of courts) in rejecting the “Hunstein theory” of liability under the Fair Debt Collection Practices Act (FDCPA). In...more

Troutman Pepper

Illinois Federal Court Dismisses FDCPA Claim for Lack of Article III Standing

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Federal courts across the country continue to divest themselves of Fair Debt Collection Practices Act (FDCPA) cases following the Supreme Court’s salient Article III standing decision in TransUnion LLC v. Ramirez. The...more

Ballard Spahr LLP

Tenth Circuit dismisses FDCPA claim for lack of standing where third party mail vendor sent collection letters

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The U.S. Court of Appeals for the Tenth Circuit recently joined the Eleventh Circuit (and a growing majority of courts) in rejecting the “Hunstein theory” of liability under the Fair Debt Collection Practices Act (FDCPA). In...more

Ballard Spahr LLP

New Jersey federal court rules misleading collection letter alone does not establish Article III standing

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In an unpublished opinion, a New Jersey federal district court has ruled that a plaintiff did not have Article III standing to assert a claim under the Fair Debt Collection Practices Act based solely on her receipt of an...more

Troutman Pepper

No License? No Standing! District Court Dismisses FDCPA Suit Against Unlicensed Debt Collector For Lack Of Standing

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On January 4, the District Court of New Jersey dismissed a Fair Debt Collection Practices Act (FDCPA) complaint against an unlicensed debt collector for lack of standing. In Valentine v. Unifund CCR, LLC, et al., the court...more

Troutman Pepper

Tenth Circuit Affirms Dismissal of FDCPA Mailer-Vendor Claims

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A recent opinion issued by the Tenth Circuit serves as further confirmation that plaintiffs bringing Fair Debt Collection Practices Act (FDCPA) claims in federal court must allege sufficient concrete injury — tangible or...more

Cozen O'Connor

Neither Confusion nor Expense of Retaining Counsel Sufficient for Article III Standing in FDCPA Case

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The U.S. Supreme Court’s 2016 decision in Spokeo Inc. v. Robins was a game-changer. That decision single-handedly raised the bar for a plaintiff alleging a violation of a consumer protection statute such as the Fair Credit...more

Hinshaw & Culbertson - Consumer Financial...

The Hunstein Saga Ends at the Eleventh Circuit: Court Determines That Use of a Mail Vendor Did Not Inflict a Concrete Injury

On September 8, 2022, the Eleventh Circuit Court of Appeals gave its final word—after many twists and turns—in Hunstein v. Preferred Collection and Management Services, Inc., No. 19-14434. The court issued an en banc opinion...more

Burr & Forman

Eleventh Circuit Clarifies Tests for Article III Standing, Changes Course on FDCPA and Mailing Vendors

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On September 8, 2022, in Hunstein v. Preferred Collection and Management Services, Inc. , No. 19-14434, the Eleventh Circuit Court of Appeals issued an en banc decision which departs significantly from the panel decision on...more

Blank Rome LLP

Fifth Circuit Holds Mere Statutory Violation of the FDCPA, Future Risk of Harm, Confusion, and Lost Time Are Insufficient to...

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Financial institutions, debt collectors, debt collection law firms, and consumer-facing businesses should take note that the Fifth Circuit Court of Appeals has ruled that merely asserting a statutory violation of the Fair...more

Troutman Pepper

NY District Court Rules Consumer With No Intent to Pay a Debt Lacks Standing in FDCPA Claim for Conflicting Collection Letters

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A consumer made charges on a credit card account, which she failed to pay as agreed. The creditor referred the account to a law firm, which served the consumer with a collection suit and obtained a default judgment for the...more

Burr & Forman

Seventh Circuit Dismisses FDCPA Claim for Lack of Standing

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In Pierre v. Midland Credit Management, Inc., — F.4th —, 2022 WL 986441 (7th Cir. Apr. 1, 2022), the Seventh Circuit affirmed the dismissal of a claim under the Fair Debt Collection Practices Act (“FDCPA”), finding that the...more

Troutman Pepper

Plaintiff’s Confusion Over Debt Collection Letter Is Not Enough to Create Standing to Assert an FDCPA Claim

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In Whitfield v. Contract Callers, Inc., Civil Action No. RDB-21-1540 (D. Md. Dec. 20, 2021), the District of Maryland dismissed claims asserted under the Fair Debt Collection Practices Act (FDCPA), holding that confusion...more

Ballard Spahr LLP

Illinois federal court rejects plaintiffs’ attempt to avoid federal court jurisdiction in cases alleging FDCPA violations based on...

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In two cases in which the plaintiffs alleged that the debt collector defendants violated the FDCPA by sharing information about their debts with third party vendors used to prepare collection letters, an Illinois federal...more

Troutman Pepper

Seventh Circuit District Court Dismisses FDCPA Case for Lack of Article III Standing

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In Friend v. CACH LLC, a district court in the Seventh Circuit dismissed a Fair Debt Collection Practices Act (FDCPA) case for lack of Article III standing. In its holding, the court emphasized that to establish Article III...more

Burr & Forman

Sixth Circuit Dismisses FDCPA Voicemail Case For Lack of Standing

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In line with the recent trend of courts giving increased scrutiny to standing in consumer finance cases, the Sixth Circuit Court of Appeals dismissed an appeal this week under the Fair Debt Collection Practices Act (“FDCPA”)...more

Troutman Pepper

Eastern District of New York Dismisses FDCPA Complaint Based on Lack of Standing

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The Eastern District of New York recently found that a plaintiff lacked Article III standing to bring her FDCPA suit as she failed to demonstrate a concrete, particularized injury. In the case of Bush v. Optio Solutions LLC,...more

Troutman Pepper

New York District Court Dismisses Six FDCPA Cases Invoking “Mailing Vendor” Theory Emanating from the Eleventh Circuit Hunstein...

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In In re FDCPA Mailing Vendor Cases, a New York district court dismissed six FDCPA complaints after plaintiffs in each of the respective cases failed to demonstrate injury-in-fact sufficient for Article III standing in...more

Ballard Spahr LLP

New York federal court dismisses six class action cases alleging FDCPA violations in reliance on Hunstein

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A New York federal district court has dismissed for lack of Article III standing six class action cases alleging that debt collectors violated the FDCPA by sharing data about the plaintiffs’ debts with mailing vendors. In...more

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