Spokeo's Impact On Eleventh Circuit FDCPA Case

The Eleventh Circuit recently released an unpublished decision regarding its opinion on the impact of Spokeo on a Fair Debt Collection Practices Act putative class action, finding that the named plaintiff satisfied Article III standing requirement.

In Church v. Accretive Health, Inc., the defendant sent the named plaintiff a letter advising her that she owed a hospital debt.  The letter allegedly did not include certain disclosures required by the FDCPA.  The plaintiff claimed that upon receiving the letter in question, she "was very angry" and "cried a lot."  Plaintiff filed suit in Alabama federal court.  The district court originally granted the defendant's motion for summary judgment, holding that the defendant was not a "debt collector" under the Act.