Keating v. Frederick Debt Management, LLC

CourtDistrict Court, D. Minnesota
DecidedSeptember 2, 2025
Docket0:24-cv-03659
StatusUnknown

This text of Keating v. Frederick Debt Management, LLC (Keating v. Frederick Debt Management, LLC) is published on Counsel Stack Legal Research, covering District Court, D. Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Keating v. Frederick Debt Management, LLC, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Maria Keating, File No. 24-cv-3659 (ECT/EMB)

Plaintiff,

v. OPINION AND ORDER

Frederick Debt Management, LLC,

Defendant.

________________________________________________________________________ Christopher Wilcox and Carl E. Christensen, Christensen Sampsel PLLC, Minneapolis, MN, for Plaintiff Maria Keating.

Plaintiff Maria Keating seeks a default judgment against Defendant Frederick Debt Management, LLC. Keating alleges that Frederick’s debt collection practices violated the Fair Debt Collection Practices Act, 15 U.S.C. § 1692, et seq. (“FDCPA”), and amounted to the tort of intrusion upon seclusion under Minnesota law. Keating’s motion will be granted, though in a slightly lower amount than she requests.1 The basic process for determining whether a default judgment should be entered is straightforward. Entry of default means that the “factual allegations of the complaint, except those relating to the amount of damages, will be taken as true.” 10A Mary K. Kane,

1 The Clerk properly entered Frederick’s default. ECF No. 9. The summons and complaint were served personally on Frederick on October 29, 2024. ECF No. 4. Frederick did not appear or respond. See generally, Docket; see also Wilcox Decl. [ECF No. 16] ¶¶ 8–9. A hearing on the motion was held on September 2, 2025. ECF No. 23. Frederick did not appear or respond to the default-judgment motion. Federal Practice and Procedure § 2688.1 (4th ed. May 2025 Update) (footnotes omitted). Thus, it must first be determined whether the taken-as-true factual allegations of the

complaint “constitute a legitimate cause of action, since a party in default does not admit mere conclusions of law.” Marshall v. Baggett, 616 F.3d 849, 852 (8th Cir. 2010) (quoting Murray v. Lene, 595 F.3d 868, 871 (8th Cir. 2010)). If the taken-as-true allegations of the complaint constitute a legitimate cause of action, then the amount and other terms of the default judgment must be ascertained. See Hagen v. Sisseton-Wahpeton Cmty. Coll., 205 F.3d 1040, 1042 (8th Cir. 2000).

Start with the factual allegations in the Complaint, which are accepted as true. Keating is a Minnesota citizen. Compl. [ECF No. 1] ¶ 5. In 2022, Frederick attempted to collect an alleged “payday lending” debt from Keating. Compl. ¶ 10. The debt was alleged to have originated from Check N’ Go, a payday lending entity. Id. Later in 2022, Keating’s counsel notified Frederick’s predecessor-in-interest, Serenity Recovery LLC, that Keating

was represented and disputed the Check N’ Go debt. Id. ¶ 12. Beginning in 2023, Frederick repeatedly sent communications directly to Keating to collect the debt from her. Id. ¶ 13. Frederick’s communications included false threats that Frederick would seek judgment against Keating if the disputed debt was not paid. Id. ¶ 14. For example, on October 18, 2023, Frederick wrote: “At the close of business on Monday 10/28/2023 the

matter with Check N Go will be closed and our office will seek judgment and wage garnishment if payment is not made.” Id. ¶ 15. Frederick has not sought judgment, never could seek judgment, and never intended to seek judgment. Id. ¶ 16. Frederick has not sought to garnish Keating’s wages, never could garnish Keating’s wages, and never intended to garnish Keating’s wages. Id. ¶ 17. Frederick made these false statements to coerce Keating into payment of the disputed debt. Id. ¶ 18.

Keating claims that Fredrick’s conduct violated 15 U.S.C. §§ 1692c(a)(2), 1692d, 1692e, 1692e(4), 1692e(5), 1692f, and the complaint’s taken-as-true factual allegations constitute a legitimate cause of action at least under 15 U.S.C. § 1692c(a)(2). Keating is a “consumer” under the FDCPA. See 15 U.S.C. § 1692a(3) (defining “consumer” as “any natural person obligated or allegedly obligated to pay any debt.”). Frederick is a “debt collector” for the FDCPA’s purposes. See 15 U.S.C. § 1692a(6); see also Kaminski v.

Frederick Debt Mgmt., LLC, No. 2:25-cv-80, 2025 WL 216705, at *1 (S. D. Ohio July 18, 2025) (“Defendant obtained the right to collect on the subject debt as a third-party debt collector within the meaning of the [FDCPA] in that it uses postal mail, an instrumentality of interstate commerce for its business, the principal purpose of which is the collection of debts, or it regularly collects or attempts to collect, directly or indirectly, debts owed or

due or asserted to be owed or due another.” (citing 15 U.S.C. § 1692a(6)). Section 1692c(a)(2) says “a debt collector may not communicate with a consumer in connection with the collection of any debt” without the consumer’s prior consent “if the debt collector knows the consumer is represented by an attorney with respect to such debt and has knowledge of, or can readily ascertain, such attorney’s name and address, unless the

attorney fails to respond within a reasonable time to a communication from the debt collector or unless the attorney consents to direct communication with the consumer[.]” 15 U.S.C. § 1692c(a)(2). Here, Frederick repeatedly sent debt collection communications directly to Keating when Frederick knew Keating was represented by counsel. Compl. ¶ 32.

After a defendant’s liability is established, a plaintiff seeking a default judgment “must still prove its actual damages to a reasonable degree of certainty.” Everyday Learning Corp. v. Larson, 242 F.3d 815, 818–19 (8th Cir. 2001). “A district court may determine damages by computing from the facts of record the amount that the plaintiff is lawfully entitled to recover and enter judgment accordingly.” Radisson Hotels Int’l, Inc. v. Fairmont Partners LLC, No. 19-cv-1176 (WMW/BRT), 2020 WL 614810, at *2

(D. Minn. Feb. 10, 2020). Here, this task is relatively straightforward. Frederick’s § 1692c(a)(2) violation means Keating is entitled to recover statutory damages not to exceed $1,000, see 15 U.S.C. § 1692k(a)(2)(a), and reasonable attorney fees and costs, 15 U.S.C. § 1692k(a)(3), among other possible remedies. Keating seeks just these sums— i.e., statutory damages, attorneys’ fees, and costs—in the total amount of $6,578.00. See

Wilcox Decl. ¶¶ 38, 41–43.2 Though the $1,000 statutory damages award is as straightforward as it gets, the law requires a close examination of Keating’s request for attorneys’ fees and costs. The party seeking fees has the burden of establishing that the fees sought are reasonable and should submit evidence supporting the rates claimed and hours worked. Hensley v. Eckerhart,

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Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blum v. Stenson
465 U.S. 886 (Supreme Court, 1984)
Marshall v. Baggett
616 F.3d 849 (Eighth Circuit, 2010)
Fox v. Vice
131 S. Ct. 2205 (Supreme Court, 2011)
Murray v. Lene
595 F.3d 868 (Eighth Circuit, 2010)
Adrian Bryant v. Jeffrey Sand Company
919 F.3d 520 (Eighth Circuit, 2019)

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Keating v. Frederick Debt Management, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/keating-v-frederick-debt-management-llc-mnd-2025.