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Parsons v. United Collections Bureau: Consumer Alleged a Concrete Injury Under FCRA Based on Claim That Collector Viewed Consumer’s Credit Report Without a Permissible Purpose

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The 4th Circuit stated for the first time that where a consumer alleged a collection agency obtained and viewed the consumer’s credit report from a CRA for an improper purpose under FCRA, the consumer stated a sufficient concrete injury for Article III standing purposes. 11/22/2022 3:00 P.M. 3.5 minute read Parsons v. United Collections Bureau, […]

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Gonzales v. Receivables Performance Mgmt: Consumer Denied Attorney’s Fees Where Collector Had Basis for Removal of Case

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A consumer filed an action alleging a collection agency violated the FDCPA by using a third-party letter vendor. Because the collector removed the case before the final Hunstein decision, the collector had an objectively reasonable basis for believing the court had subject matter jurisdiction at the time of removal. Accordingly, the court denied the consumer’s […]

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Mullins v. Monarch Recovery: Court Rejects Joint Motion by Consumer and Collector Seeking Federal Jurisdiction

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A consumer alleged a collector violated the FDCPA by using a third-party letter vendor, but did not allege that anyone read her private information. Accordingly, the consumer did not sufficiently plead the harm that an “invasion of privacy” claim based on public disclosure intends to remedy, therefore the consumer could not maintain Article III standing […]

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Dorian v. Community Loan Servicing: Credit Report Involving Commercial Properties Does Relate to Consumer Report Under FCRA

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A consumer’s allegations that the credit reports at issue were consumer reports under the FCRA were entirely conclusory and subject to dismissal because the claims did not allege any facts relating to their purpose, such as for personal, family or household purposes. 10/19/2022 2:30 P.M. 4 minute read Dorian v. Community Loan Servicing, LLC, No. […]

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Navarroli v. Medicredit: Applying the Final Hunstein Decision, Court Finds Consumer Lacked a Concrete Injury, Remanded FDCPA Claims

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Congress did not appear to intend for the FDCPA to extend so far as to prevent debt collectors from enlisting the assistance of mailing vendors to perform ministerial duties, such as printing and stuffing the debt collector’s letters. 09/27/2022 2:45 P.M. 4 minute read Navarroli v. Medicredit, Inc., No. 21-CV-6203, 2022 WL 4465840 (N.D. Ill. […]

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