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FDCPA – Subject-matter Jurisdiction

By: Derek Hawkins//November 1, 2021//

FDCPA – Subject-matter Jurisdiction

By: Derek Hawkins//November 1, 2021//

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7th Circuit Court of Appeals

Case Name: Audrey Wadsworth v. Kross, Liberman & Stone, Inc.,

Case No.: 19-1400

Officials: SYKES, Chief Judge, and FLAUM and ROVNER, Circuit Judges.

Focus: FDCPA – Subject-matter Jurisdiction

This case presents a problem that has become familiar to our circuit: alleged violations of the Fair Debt Collection Practices Act that have not caused the plaintiff any concrete harm. These claims allege nothing more than “bare procedural violation[s],” which Article III precludes us from adjudicating. Spokeo, Inc. v. Robins, 136 S. Ct. 1540, 1549 (2016). We therefore reverse and remand with instructions to dismiss for lack of subject-matter jurisdiction.

Reversed and remanded with instructions to dismiss

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Derek A Hawkins is Corporate Counsel, at Salesforce.

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