On December 15, 2020, the Seventh Circuit Court of Appeals
decided four cases which all dealt with the issue of standing
within the context of the Fair Debt Collection Practices Act
("FDCPA"). With these holdings, the Seventh Circuit
stated that simply alleging a procedural violation, confusion, or
annoyance under the FDCPA does not constitute an injury-in-fact and
that plaintiffs need to show real harm resulting from their
responses to debt collectors' actions to have Article III
standing in federal court.
In Bazile v. Finance System of Green Bay
Inc., Sandra Bazile ("Bazile") alleged that
Finance System of Green Bay ("FSGB") sent her a dunning
letter seeking to collect medical debts she incurred. She further
alleged that the letter did not indicate whether the amount owed
may increase with the accrual of interest and that the exclusion of
this information was a violation of the FDCPA because the letter
was misleading and did not provide "the amount of the
debt,"
