Pennell v. Global Trust Management, LLC

Plaintiff-debtor lacked standing to pursue her action under Fair Debt Collection Practices Act, alleging that defendant-debt collector violated section 1692c(a)(2) by directly communicating with plaintiff after plaintiff notified defendant that she refused to pay debt and/or told defendant to stop communicating with her. While Dist. Ct. granted defendant's motion for summary judgment based on finding that defendant lacked knowledge of plaintiff's cease-communication request, Dist. Ct. should have dismissed case for lack of standing for failure to allege concrete and particularized injury, where plaintiff merely alleged that defendant's dunning letter cause her stress and confusion, which, without any physical manifestation or qualified medical diagnosis, is not sufficient to establish Article III standing.