Dist. Ct. did not err in dismissing for lack of Article III standing plaintiff-debtor’s action, alleging that defendant-debt collector violated Fair Debt Collection Practices Act, when it sent two collections letters, approximately one year apart, about plaintiff’s debt that had been discharged in bankruptcy. Dist Ct. could properly find that plaintiff failed to allege that he had suffered any concrete injury in fact, where he alleged only that he suffered confusion, stress, concern, and fear arising out of receipt of defendant’s collection letters. Plaintiff also failed to allege that defendant took any steps to report plaintiff’s discharged debt to any other agency. Ct. of Appeals rejected plaintiff’s claim that his allegations of intangible damages correlated to common law torts of invasion of privacy and intrusion upon exclusion, and thus were sufficiently concrete injuries for purposes of standing to sue. (Dissent filed.)
Federal 7th Circuit Court
Civil Court
Standing