In 2010, the United States Supreme Court expanded the concept of
"corporate personhood" when it held in Citizens United v. FEC, 558 U.S. 310, 130
S. Ct. 876, 175 L. Ed. 2d 753 (2010), that corporations can
engage in political speech protected by the First Amendment. The
same rationale carried over to the religious context in Burwell v. Hobby Lobby Stores, Inc., 134
S. Ct. 2751, 189 L. Ed. 2d 675 (2014), when the Court decided
closely-held corporations have religious liberties under the
Religious Freedom Restoration Act.
Now it appears legal entities might
be entitled to protection under a federal consumer protection
statute too, at least in the Sixth Circuit.
Last week, the Sixth Circuit Court
of Appeals, in Anarion Invs., LLC v. Carrington Mortg.
Servs., 2015 U.S. App. LEXIS 12670 (July 23, 2015),
created a new class of plaintiffs entitled to sue under the federal
Fair Debt Collection Practices Act, 15 U.S.C. 1692 et seq.
(the "FDCPA" or the "Act") when it ruled
