In a recent opinion issued by the U.S. District Court for the Western District of Pennsylvania in Hartman v. Medicredit, Inc. (United States District Court, W.D. Pennsylvania, Case No. 15-1596), Chief United States Magistrate Judge Maureen P. Kelly rejected an argument brought by the defendant relying on Spokeo v. Robbins, (136 S.Ct. 1540 (2016) (Spokeo) suggesting that an alleged violation of the Fair Debt Collection Practices Act (FDCPA) did not create a “concrete injury” to give standing to the Plaintiff.Judge Kelly recommended that defendant Medicredit’s Motion to Dismiss a case about violating the Fair Debt FDCPA by sending collection letters that exposed personal identifying information be denied.
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