Adams v. Skagit Bonded Collectors LLC

CourtDistrict Court, W.D. Washington
DecidedJanuary 22, 2020
Docket2:19-cv-01005
StatusUnknown

This text of Adams v. Skagit Bonded Collectors LLC (Adams v. Skagit Bonded Collectors LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Adams v. Skagit Bonded Collectors LLC, (W.D. Wash. 2020).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 6 AT SEATTLE 7 BRETT ADAMS, on behalf of himself and all others similarly situated, 8 Plaintiff, 9 C19-1005 TSZ v. 10 ORDER SKAGIT BONDED COLLECTORS, 11 LLC dba SB&C, LTD., 12 Defendant. 13 THIS MATTER comes before the Court on defendant’s motion for judgment on 14 the pleadings pursuant to Federal Rule of Civil Procedure 12(c), docket no. 15. Having 15 reviewed all papers filed in support of, and in opposition to, the motion, the Court enters 16 the following order. 17 Background 18 Plaintiff Brett Adams brings this putative class action against defendant Skagit 19 Bonded Collectors, LLC dba SB&C, Ltd., alleging violations of two provisions of the 20 Fair Debt Collection Practices Act (“FDCPA”), namely 15 U.S.C. § 1692g(a)(2) and 15 21 U.S.C. § 1692e. See Compl. (docket no. 1). Plaintiff received four different letters from 22 1 defendant indicating that the described accounts had “been assigned to [defendant’s] 2 office for collection.” See Ex. A to Compl. (docket no. 1-1). Each letter was dated

3 January 21, 2019, and identified the “Original Creditor” as Skagit Regional Health. Each 4 letter referenced a unique creditor account number, and indicated that “no payment was 5 received.” Id. The letters recited that the following amounts were owed: 6 Principal Interest and Account No. Balance Service Fees Total Due 7 H█████873 $ 20.00 $ 0.60 $ 20.60 8 H█████427 $ 20.00 $ 0.60 $ 20.60 9 H█████860 $2,350.90 $ 71.30 $2,422.20 10 H█████406 $2,874.00 $ 87.16 $2,961.16 11 Id. Plaintiff contends that each letter fails to identify the current creditor as required by 12 the FDCPA. Defendant seeks judgment on the pleadings, arguing that the letters do not 13 violate either § 1692g(a)(2) or § 1692e, and that plaintiff lacks standing. 14 Discussion 15 A. Standard for Judgment on the Pleadings 16 Judgment on the pleadings is proper when no issues of material fact exist, and the 17 moving party is entitled to judgment as a matter of law. See Gen’l Conference Corp. of 18 Seventh-Day Adventists v. Seventh-Day Adventist Congregational Church, 887 F.2d 228, 19 230 (9th Cir. 1989); see also Fed. R. Civ. P. 12(c). In deciding a motion for judgment on 20 the pleadings, the Court must accept as true all allegations of fact by the party opposing 21 the motion, and must construe the pleadings in the light most favorable to the non- 22 1 moving party. See McGlinchy v. Shell Chem. Co., 845 F.2d 802, 810 (9th Cir. 1988). In 2 this matter, the facts are undisputed, and the issue before the Court is solely whether, as a

3 matter of law, the language of defendant’s “dunning” letters complies with the FDCPA. 4 See McBroom v. Syndicated Office Sys., LLC, 2018 WL 6199014 at *2 (W.D. Wash. 5 Nov. 28, 2018) (“When all relevant facts are undisputed, ‘the application of the FDCPA 6 to those facts is a question of law.’” (citing Sheriff v. Gillie, 136 S. Ct. 1594, 1603 n.7 7 (2016))). 8 B. The Requirements of the FDCPA

9 Under FDCPA, a debt collector must, in connection with an attempt to collect a 10 debt from a consumer, send a written notice containing “the name of the creditor to 11 whom the debt is owed.” 15 U.S.C. § 1692g(a)(2). The FDCPA further prohibits a debt 12 collector from using a “false, deceptive, or misleading representation” in trying to collect 13 a debt. 15 U.S.C. § 1692e. Plaintiff asserts that defendant’s inclusion in its dunning

14 letters of the “Original Creditor,” without a concomitant identification of the “current” 15 creditor, violates these provisions of the FDCPA. 16 The question presented by plaintiff has been litigated in various districts across the 17 country, producing a split of authorities. Compare Kirkpatrick v. TJ Servs., Inc., 379 18 F. Supp. 3d 539 (E.D. Va. 2019) (denying the debt collector’s Rule 12(b)(6) motion), and

19 Anderson v. Ray Klein, Inc., 2019 WL 1568399 (E.D. Mich. Apr. 10, 2019) (denying the 20 debt collector’s Rule 12(c) motion), with Smith v. Simm Assocs., Inc., 926 F.3d 377 21 (7th Cir. 2019) (affirming the grant of summary judgment in favor of the debt collector), 22 and Warner v. Ray Klein, Inc., 2018 WL 1865873 (D. Ore. Apr. 18, 2018) (granting the 1 debt collector’s motion for summary judgment).1 The Ninth Circuit has not yet spoken. 2 The Court is persuaded by the reasoning of the Seventh Circuit and the District of

3 Oregon, and concludes that plaintiff cannot, as a matter of law, establish a violation of the 4 FDCPA. 5 The FDCPA is a remedial statute designed to curb abusive debt collection 6 practices. See Gonzales v. Arrow Fin. Servs., LLC, 660 F.3d 1055, 1060 (9th Cir. 2011). 7 It comprehensively regulates the conduct of debt collectors and imposes strict liability, 8 requiring no proof of intent or other mens rea. Id. at 1060-61. In evaluating, under the

9 FDCPA, whether a consumer would be deceived or misled by a communication, the 10 Court must apply the “least sophisticated debtor” standard, which examines the effect on 11 individuals of “below average sophistication or intelligence” or who are “uninformed or 12 naive.” Id. at 1061-62. This standard presumes “a basic level of understanding and 13

14 1 A number of other district courts have also ruled in favor of the debt collector, but those cases 15 involve slightly different facts. See Baker v. Lanier Collection Agency & Servs. Inc., 2018 WL 3109667 (D.S.C. June 25, 2018) (involving a dunning letter beginning with “Re: GEORGIA 16 EMERGENCY ASSOCIATES” and stating that the account had been “placed” with the debt collector); Santibanez v. Nat’l Credit Sys., Inc., 2017 WL 126111 (D. Ore. Jan. 12, 2017) (also 17 using the terms “Re:” and “placed”); see also McBroom v. Syndicated Office Sys., LLC, 2018 WL 6199014 (W.D. Wash. Nov. 28, 2018) (identifying the creditor at issue as the “Facility”); 18 Wright v. Phillips & Cohen Assocs., Ltd., 2014 WL 4471396 (E.D.N.Y. Sep. 10, 2014) (naming the “Original Creditor,” as well as the “Client,” which had “referred” the matter for collection); Schuerkamp v. Afni, Inc., 2011 WL 5825969 (D. Ore. 2011) (containing “Creditor” in a table 19 heading, without either “original” or “current” as a modifier). Another Seventh Circuit opinion, Janetos v. Fulton Friedman & Gullace, LLP, 825 F.3d 317 (7th Cir. 2016), which favors the 20 debtor, rather than the debt collector, is likewise distinguishable. In Janetos, the dunning letter started with “Re: Asset Acceptance, LLC Assignee of AMERISTAR,” indicated that the account 21 had been “transferred” to the debt collector, and provided both the “Original Creditor’s” and the debt collector’s account numbers. Id. at 320. The Janetos Court concluded that these statements 22 taken together “simply did not say who currently owned the debts.” Id. at 321. 1 willingness to read with care,” and eschews any “bizarre,” “idiosyncratic,” or “peculiar” 2 interpretations. Id. at 1062.

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Adams v. Skagit Bonded Collectors LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/adams-v-skagit-bonded-collectors-llc-wawd-2020.