Wadsworth v. Kross, Lieberman & Stone, Inc.

Dist. Ct. lacked jurisdiction to consider plaintiff’s claim under Fair Debt Collection Practices Act (FDCPA), where plaintiff alleged that defendant-debt collector failed to provide complete written notice of her statutory rights within five days of defendant’s debt collection letter and failed to identify herself as debt collector or stated that she was attempting to collect debt in subsequent telephone call. Plaintiff lacked standing to pursue her FDCPA claim, where plaintiff could not show in response to defendant’s motion for summary judgment that she suffered concrete injury that was traceable to her purely procedural FDCPA violations. Moreover, plaintiff did not allege that she paid any money that she should not have paid or disputed, and plaintiff’s contention that she incurred only emotional harms arising out of instant alleged violations was insufficient to constitute injury in fact to support her standing to bring instant action.