Paul Hill v. Accounts Receivable Services
888 F.3d 343
| 8th Cir. | 2018Background
- Accounts Receivable sued Paul Hill in Minnesota conciliation court on an assigned medical debt (~$2,997) and sought statutory interest.
- At the conciliation hearing Accounts Receivable submitted exhibits purporting to document the assignment; Hill challenged their authenticity.
- The conciliation court entered judgment for Hill on a standard form stating plaintiff failed to demonstrate entitlement to relief and recovered zero.
- Hill filed suit under the Fair Debt Collection Practices Act (15 U.S.C. § 1692 et seq.), alleging false, deceptive, or misleading representations and unfair collection practices.
- The district court granted Accounts Receivable’s motion for judgment on the pleadings; Hill appealed the interpretation of § 1692e and § 1692f issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether § 1692e requires materiality for false or misleading statements | Hill: any false statement by a debt collector is actionable; no materiality requirement | Accounts Receivable: courts apply a materiality standard; immaterial inaccuracies are not actionable | Court: adopts materiality standard for § 1692e; affirms that immaterial falsehoods are not actionable |
| Whether submitting allegedly inauthentic or inaccurate documents to court violated § 1692e | Hill: documents contained false statements and misrepresented authenticity, so conduct was materially misleading | Accounts Receivable: loss of collection action or imperfect documentation alone does not show actionable falsity | Court: inadequate documentation and alleged inaccuracies were not material; no § 1692e violation |
| Whether asserting entitlement to statutory interest violated § 1692f(1) by seeking amounts not permitted by law | Hill: defendant sought unauthorized interest (claimed impermissible statute) | Accounts Receivable: sought interest under Minnesota § 334.01; its claim was legally plausible and not clearly unauthorized | Court: question of state law unsettled; § 334.01’s text does not bar recovery here; not an unfair-collection violation |
| Whether bringing and pursuing the conciliation action itself violated the Act | Hill: filing and pursuing suit with flawed evidence was an action that cannot legally be taken | Accounts Receivable: bringing suit that later fails is not per se unlawful | Court: bringing a suit that proves unsuccessful does not by itself violate the Act; no § 1692 violation on that basis |
Key Cases Cited
- Hahn v. Triumph P’ships LLC, 557 F.3d 755 (7th Cir.) (materiality required for § 1692e claims)
- Elyazidi v. SunTrust Bank, 780 F.3d 227 (4th Cir.) (applies materiality standard to § 1692e)
- Jensen v. Pressler & Pressler, 791 F.3d 413 (3d Cir.) (materiality requirement for § 1692e)
- Miller v. Javitch, Block & Rathbone, 561 F.3d 588 (6th Cir.) (materiality analysis under § 1692e)
- Donohue v. Quick Collect, Inc., 592 F.3d 1027 (9th Cir.) (§ 1692e materiality application)
- Janson v. Katharyn B. Davis, LLC, 806 F.3d 435 (8th Cir.) (rejecting per se rule that any false statement is a § 1692e violation)
- Hemmingsen v. Messerli & Kramer, P.A., 674 F.3d 814 (8th Cir.) (unsuccessful suit alone does not establish an Act violation)
- Heintz v. Jenkins, 514 U.S. 291 (Supreme Court) (bringing a civil action can be debt-collection activity under the FDCPA)