Franklin v. Parking Revenue Recovery Services, Inc., 832 F.3d 741

Carmen Franklin and Jenifer Chism parked in a Metra commuter-rail parking lot operated by CPS; signs and pay machine stated $1.50/day and a possible penalty for nonpayment (up to $60).
CPS claimed Franklin and Chism did not pay, assessed a $1.50 fee plus a $45 nonpayment penalty, and referred the accounts to Parking Revenue Recovery Services, Inc. (Parking Revenue).
Parking Revenue sent collection letters demanding payment of the total and stating the amount as "this debt," and advising recipients to dispute the debt in writing.
Franklin and Chism filed a putative class action asserting the collection letters violated the Fair Debt Collection Practices Act (FDCPA), 15 U.S.C. §§ 1692 et seq.
The district court granted summary judgment for Parking Revenue, reasoning the obligations were fines/ticket-like (not arising from contract) and thus not "debts" under §1692a(5).
The Seventh Circuit reversed, holding the parking obligation arose from a contract formed when defendants accepted CPS’s offer to park at posted rates, so the FDCPA applies to the collection efforts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether unpaid parking fees and the nonpayment penalty are "debts" under FDCPA §1692a(5)	Franklin: parking at a lot with posted terms is a transaction; the resulting obligation is a debt governed by FDCPA	Parking Revenue: obligations are fines/tickets (like municipal meter fines) or akin to theft-based tort obligations, not contractual debts covered by FDCPA	Held: The obligations arise from contract formed by parking under posted terms, so they are "debts" within §1692a(5) and FDCPA applies

Bass v. Stolper, Koritzinsky, Brewster & Neider, S.C., 111 F.3d 1322 (7th Cir. 1997) (defines "transaction" broadly and explains FDCPA covers obligations arising from contract rather than tort or regulatory duties)
Townsend v. Cooper, 759 F.3d 678 (7th Cir. 2014) (summary judgment review standard cited)