DIETZ v. MED-1 SOLUTIONS, LLC
24f4th1146
S.D. Ind.2022Background
- Melissa Dietz incurred an unpaid medical debt to Community Health Network that Med‑1 Solutions later sought to collect.
- In October 2019 Dietz retained counsel about bankruptcy; she had not paid the debt nor filed bankruptcy before receiving collection letters.
- On November 4, 2019 Dietz received two collection letters from Med‑1, each signed by a different Med‑1 attorney; the duplicate letters made her worried, stressed, and lose sleep.
- Dietz gave the letters to her bankruptcy attorney; she did not make payments or file bankruptcy in response to the letters.
- Dietz sued under the FDCPA § 1692e(3), alleging the letters misleadingly implied the attorneys were personally involved; both parties moved for summary judgment.
- The district court granted Med‑1’s motion and denied Dietz’s, holding Dietz lacked Article III standing because she suffered no concrete injury traceable to the letters.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dietz has Article III standing (injury‑in‑fact) | Dietz claims concrete injury from confusion, stress, lost sleep, and altered decision‑making about paying vs. bankruptcy | Med‑1 argues no concrete injury: Dietz did not suffer monetary or physical harm nor take any detrimental action traceable to the letters | No standing — Dietz failed to show a concrete, traceable, redressable injury; case dismissed for lack of jurisdiction |
| Whether the letters violated FDCPA §1692e(3) by implying attorneys’ personal involvement | Letters misleadingly implied attorneys were personally involved in collection | Any statutory defect did not cause a concrete injury and thus cannot support jurisdiction; Med‑1 also contests the misleadingness | Court did not find a cognizable injury and therefore did not rely on a substantive FDCPA ruling; judgment for Med‑1 |
| Whether emotional distress and sleep loss are concrete injuries | Dietz: stress and sleeplessness from the letters are concrete harms | Med‑1: pure psychological harms without physical manifestations or a medical diagnosis are not concrete under controlling precedent | Emotional distress/sleep loss alone insufficient to confer standing |
| Whether Dietz took detrimental action in reliance on the letters | Dietz: the letters affected her decision‑making about payment vs. bankruptcy | Med‑1: Dietz made no payment, no promise to pay, and did not file bankruptcy; she only gave letters to counsel | No detrimental action shown; therefore no standing under the FDCPA reliance/detriment line of cases |
Key Cases Cited
- American Family Mutual Insurance Co. v. Williams, 832 F.3d 645 (7th Cir. 2016) (standard for evaluating cross‑motions for summary judgment)
- Celotex Corp. v. Catrett, 477 U.S. 317 (1986) (summary judgment burden shifting)
- Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (standing elements)
- Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (concrete‑injury requirement)
- TransUnion LLC v. Ramirez, 141 S. Ct. 2190 (2021) (limits on statutory violations producing concrete injury)
- Pierre v. Midland Credit Management, Inc., 29 F.4th 934 (7th Cir. 2022) (FDCPA standing; detrimental action required)
- Wadsworth v. Kross, Lieberman & Stone, 12 F.4th 665 (7th Cir. 2021) (procedural FDCPA violations alone do not establish concrete injury)
- Brunett v. Convergent Outsourcing, Inc., 982 F.3d 1067 (7th Cir. 2020) (detrimental action requirement under FDCPA)
- Cothron v. White Castle System, Inc., 20 F.4th 1156 (7th Cir. 2021) (examples of tangible harms in standing analysis)
- Ewing v. MED‑1 Solutions, LLC, 24 F.4th 1146 (7th Cir. 2022) (analyzing common‑law tort analogy in FDCPA standing context)