CHAPMAN v. AA ACTION COLLECTION CO., INC.

CourtDistrict Court, D. New Jersey
DecidedFebruary 15, 2023
Docket2:21-cv-04175
StatusUnknown

This text of CHAPMAN v. AA ACTION COLLECTION CO., INC. (CHAPMAN v. AA ACTION COLLECTION CO., INC.) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
CHAPMAN v. AA ACTION COLLECTION CO., INC., (D.N.J. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY

KELLIE CHAPMAN, on behalf of herself and all others similarly situated, Plaintiff, Civ. No, 2:21-cv-04175 (WJM)

v. OPINION AA ACTION COLLECTION CO., INC, doing business as AA ACTION COLLECTION COMPANY, CHULSKY KAPLAN, LLC, AND JOHN DOES 1-25, Defendants.

WILLIAM J. MARTINI, U.S.D.J.: In this is putative class action for violations of the Fair Debt Collection Practices Act, 15 U.S.C. § 1692 ef seg., (““FDCPA”), the Court denied without prejudice the motion of Defendant AA Action Collection Co., Inc., D/B/A AA Action Collection Company’s (“AA” or “Defendant”) for Fed. R. Civ. P. 56 summary judgment, ECF No. 25, and the cross motion for summary judgment by Plaintiff Kellie Chapman’s (“Plaintiff”), ECF No. 33, pending the Court’s determination of whether it has subject matter jurisdiction. ECF No. 45. The Court decides the matter without oral argument. Fed. R. Civ. P. 78(b). For the reasons set forth below, the Complaint is dismissed for lack of standing.

I. BACKGROUND! AND PROCEDURAL HISTORY Sometime prior to October 22, 2020, Plaintiff incurred one or more financial obligations arising out of a transaction with Livingston Subspecialty Group, LLC (“LSG”), a New Jersey healthcare provider. Pl.’s Statement of Material Facts Not in Dispute (“PSUME”) at §f] 4, 9, ECF, 33-2. After the obligations became past due, LSG sent AA the Debt for collection. fd. at §§ 5-7; Todd Bank Certification in Support of Defs.’ Mot. to Dismiss (“Bank Cert.”)? at 2-3, ECF No. 25-1. On September 26, 2018, AA sent a debt collection letter to Plaintiff indicating, among other things, that if she did not dispute the $300 outstanding balance (“Debt”) within 30 days, her account may be reported to credit

| ‘The facts are taken from allegations in the Complaint and the Parties’ submissions in support of their respective summary judgment motions, ? Although Defendant’s motion was one for summary judgment, the Bank Cert, is captioned as a “Certification in support of Defendant’s Motion to Dismiss and Sanctions,”

reporting agencies. See Bank Cert., Sch. A, ECF No. 25-2. On October 30, 2018, AA sent Plaintiff a second debt collection letter informing her that that would be the last and final written notice regarding the Debt before her account would be scheduled to be reported to the credit reporting agencies. Jd. at Sch. C. Thereafter, on or about November 30, 2018, AA reported the unpaid Debt to TransUnion, PSUMEF at { 22; Bank Cert. at 9. Nearly two years later, because Plaintiff did not recognize the creditor LSG on her credit reports, Plaintiff faxed a letter dated October 22, 2020 to AA disputing the Debt and requesting verification and proof of the balance owed (“Dispute Letter”), See Compl., Ex. A, ECF No, 1-2; PSUME at 9 17-21; Cert. of Kellie Chapman (“Chapman Cert.”) at 4- 6, ECF No, 33-4. Proof of a 42 second fax transmission on October 20, 2020 is attached to the Cert. of Joseph Kk. Jones, Esq. (“Jones Cert.”), Ex. 2 at CHAP16, ECF 33-5. AA denies that it received the Dispute Letter or that Plaintiff ever responded in any capacity to the debt collection letters. Bank Cert. at #10. On December 24, 2020, Plaintiff reviewed her TransUnion credit report, which does not indicate that the Debt is disputed but does state: “Date Updated: 12/18/2020.” PSUMF at fff 23-26, Ex. 2 at CHAP16, ECF No. 33-5. On March 5, 2021, Plaintiff filed a putative class action claiming violations of §§ 1692e(2)(A), 1692e(8), and 1692e(10) of the FDCPA.? Plaintiff maintains that by failing to communicate to one or more of the credit reporting bureaus that the Debt was disputed, AA falsely or deceptively represented or made a misleading representation as to the character or legai status of her Debt in violation of the FDCPA. Subsequently, Defendant filed a motion for summary judgment arguing that Plaintiffs claims are time-barred, Plaintiff cross moved for summary judgment. The Court denied those motions without prejudice stating it would re-list the motions if it found subject matter jurisdiction to exist. After giving the parties the opportunity to address whether Plaintiff was concretely harmed and had Article III standing to bring her claims, see Order dated October 5, 2022, ECF No. 41; see also Fed. R. Civ. P. 56(f); Lee v. Sixth Mount Zion Baptist Church of Pittsburgh, 903 F.3d 113, 118 (d Cir. 2018), the Court now addresses the standing issue.

US.CA, § 1692e provides in pertinent part: A debt collector may not use any false, deceptive, or misleading representation or means in connection with the collection of any debt. ... [T]he following conduct is a violation of this section: ... (2) The false representation of — (A) the character, amount, or legal status of any debt; or... (8) Communicating or threatening to communicate to any person credit information which is known or which should be known to be false, including the failure to communicate that a disputed debt is disputed, ... (10) The use of any false representation or deceptive means to collect or attempt to collect any debt or to obtain information concerning a consumer, (emphasis added).

II. DISCUSSION Article HI of the Constitution limits the jurisdiction of federal courts to “Cases” and “Controversies.” U.S, Art. IIT § 2. The burden of establishing jurisdiction rests with the party invoking federal court jurisdiction, Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016), as revised (May 24, 2016); Animal Sci. Prod., Inc. v. China Minmetals Corp., 654 F.3d 462, 470 Gd Cir. 2011), Plaintiffs must “clearly ... allege facts demonstrating” ail three elements of constitutional standing: (1) an “injury in fact,” (2) that is “fairly traceable” to a defendant's conduct, and that (3) is likely to be redressed by favorable judicial intervention. Lujan v. Defs. Of Wildlife, 504 U.S. 555, 561 (1992). To establish an “injury in fact,” a plaintiff must show “an invasion of a legally protected interest which is (a) concrete and particularized ... and (b) actual or imminent, not conjectural or hypothetical.” fd. at 560 (citations omitted), Concrete injuries can be tangible or intangible. See TransUnion LLC y, Ramirez, 141 §, Ct. 2190, 2204 (2021). In determining whether “an intangible harm constitutes injury in fact,” the first inquiry is “whether an alleged intangible harm has a close relationship to a harm that has traditionally been regarded as providing a basis for a lawsuit in English or American courts.” Spokeo, 578 U.S. at 340. For instance, various intangible injuries such as “reputational harms, disclosure of private information, and intrusion upon seclusion,” can be concrete, TransUnion, 1418, Ct. at 2204. Another consideration in determining whether harm is sufficiently concrete is the decision of Congress to elevate “’to the status of legally cognizable injuries concrete, de facto injuries that were previously inadequate in law.’” Spokeo, 578 U.S. at 341 (citing Lujan, 504 U.S. at 578). However, even in the context of a statutory violation, Article II] standing requires a concrete injury. Jd. at 341.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Llewellyn v. Allstate Home Loans, Inc.
711 F.3d 1173 (Tenth Circuit, 2013)
Wilhelm v. Credico, Inc.
519 F.3d 416 (Eighth Circuit, 2008)
Romaine v. Kallinger
537 A.2d 284 (Supreme Court of New Jersey, 1988)
Feggans v. Billington
677 A.2d 771 (New Jersey Superior Court App Division, 1996)
Darakjian v. Hanna
840 A.2d 959 (New Jersey Superior Court App Division, 2004)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
CHAPMAN v. AA ACTION COLLECTION CO., INC., Counsel Stack Legal Research, https://law.counselstack.com/opinion/chapman-v-aa-action-collection-co-inc-njd-2023.