Rhone v. Medical Business Bureau, LLC

Dist. Ct. erred in finding that defendant had violated section 1692e(2)(A) of Fair Debt Collection Practices Act (FDCPA) when defendant misrepresented “character” of plaintiff’s debt by reporting to credit bureau that plaintiff had nine unpaid bills of $60 each to same creditor, rather than single unpaid bill of $540. There was no violation, where: (1) “character” of debt refers only to kind of obligation; and (2) number of transactions between debtor and single merchant does not affect genesis, nature or priority of said debt. Moreover, debt collector accurately informed credit bureau that debtor incurred her debt over nine transactions, and, if plaintiff’s argument was correct, report of single $540 debt to credit bureau, as advocated by plaintiff, would be misleading and also violate FDCPA, since plaintiff did not owe $540 for any transaction.