Zablocki v. Merchants Credit Guide Co.

Federal 7th Circuit Court
Civil Court
Fair Debt Collection Practices Act
Citation
Case Number: 
No. 19-2045
Decision Date: 
July 28, 2020
Federal District: 
N.D. Ill., E. Div.
Holding: 
Affirmed

Dist. Ct. did not err in dismissing for failure to state viable cause of action plaintiffs-debtors’ action under Fair Debt Collection Practices Act (FDCPA), alleging that defendant-debt collector’s practice of reporting obligations to single creditor separately instead of in aggregate fashion constituted unfair way to collect debts under section 1692f of FDCPA. It is reasonable and not deceptive for debt collector to report individually accurate debts that correspond to different charges, and that said practice was not within plain meaning of “unfair” or “unconscionable” in context of FDCPA. Moreover, plaintiffs’ proposed debt-reporting rule requiring single aggregate total of debt to single creditor would conceal debt-specific information that other consumers may prefer to see on their credit reports. Fact that plaintiffs’ credit scores would have been higher had defendant reported debts in aggregated manner did not require different result.