Jackson v. Blitt & Gaines, P.C.

Dist. Ct. did not err in dismissing for failure to state cause of action plaintiffs’ complaints alleging that defendant’s wage-garnishment actions violated Fair Debt Collection Practices Act (FDCPA) because they were filed in wrong venue. Ct. of Appeals found that instant wage-garnishment actions are actually proceedings against employer, as opposed to debtor, and thus are not covered proceedings under FDCPA.