Freddie Garland v. Orlans, PC, 999 F.3d 432

Orlans, PC (acting for Wells Fargo) sent standardized letters on law‑firm letterhead to Freddie and Linda Garland stating Wells Fargo had referred their mortgage to Orlans for foreclosure but that foreclosure‑prevention alternatives might still be available.
The letter was a form communication, signed in typed form as “Orlans PC;” Garland alleged it implied attorney involvement and an independent legal review when none occurred.
Garland sued as a putative class under the Fair Debt Collection Practices Act (FDCPA) and Michigan’s Regulation of Collections Practices Act (RCPA), alleging deceptive communications that falsely suggested attorney review.
The district court dismissed the FDCPA claim and declined supplemental jurisdiction over the RCPA claim; the Sixth Circuit affirmed but on different grounds.
The Sixth Circuit held Garland lacked Article III standing (no concrete injury and no traceability), so the federal court lacked jurisdiction to decide his statutory claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Garland suffered an Article III injury‑in‑fact (concreteness) from alleged confusion and anxiety caused by the letter	Garland: the misleading attorney‑style letter caused confusion and anxiety, which are concrete injuries supporting standing	Orlans: confusion and anxiety are intangible and insufficiently concrete under Spokeo and related precedent	Held: Confusion is not a cognizable injury; a bare allegation of anxiety is not a concrete injury under Spokeo and Buchholz
Whether the alleged anxiety is traceable to Orlans' conduct (causation/traceability)	Garland: the letter caused his anxiety about foreclosure risk	Orlans: the anxiety stems from Garland’s own default and fear of foreclosure, not the letter; therefore it is self‑inflicted and not traceable to Orlans	Held: Anxiety is not traceable to Orlans—the fear flows from Garland’s own delinquency, so traceability fails
Whether a statutory procedural violation (FDCPA/RCPA) alone can confer standing (Spokeo risk‑of‑harm pathway)	Garland did not allege a separate risk‑of‑harm theory but relied on statutory violation producing anxiety	Orlans: absent a concrete, cognizable harm or a pleaded risk of real harm to a congressionally protected interest, the statutory violation alone cannot confer Article III standing	Held: Court did not apply the risk‑of‑harm pathway because Garland did not plead it; statutory violation alone insufficient here

Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (framework for assessing when statutory/intangible harms satisfy Article III concreteness)
Buchholz v. Meyer Njus Tanick, PA, 946 F.3d 855 (6th Cir. 2020) (anxiety from an attorney‑letterhead collection letter insufficient for standing)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Article III injury‑in‑fact elements)
Clapper v. Amnesty Int’l USA, 568 U.S. 398 (2013) (future‑harm standing requires harm that is certainly impending)
Macy v. GC Servs. Ltd. P’ship, 897 F.3d 747 (6th Cir. 2018) (explains Spokeo risk‑of‑harm pathway for procedural‑violation claims)
Brunett v. Convergent Outsourcing, Inc., 982 F.3d 1067 (7th Cir. 2020) (confusion alone is not an Article III injury)
Donovan v. FirstCredit, Inc., 983 F.3d 246 (6th Cir. 2020) (risk‑of‑harm analysis required when plaintiff’s alleged injury is based on risk)