Markakos v. Medicredit, Inc.

Dist. Ct. did not err in dismissing without prejudice plaintiff-debtor's Fair Debt Collection Practices Act (FDCPA) action, alleging that defendant-debt collector sent letters to plaintiff that stated inconsistent debt amounts and unclearly identified plaintiff's creditor. Plaintiff lacked standing to sue defendant under FDCPA because she failed to allege that instant letters harmed her in any way. Moreover, plaintiff admitted that she did not pay anything extra on her debt, and that she properly disputed alleged debt that was not warranted. Also, plaintiff's alleged injury that she was confused and aggravated by defendant's letters did not constitute sufficient injury in fact to support Article III standing to pursue instant lawsuit. Too, plaintiff's mere allegation of FDCPA statutory violation alone does not cause injury in fact.