Samples v. Medicredit, Inc., 3:18-cv-00418

Plaintiff Stephen Samples sued Medicredit, Inc., alleging its debt-collection letter failed to meaningfully convey the name of the creditor in violation of 15 U.S.C. § 1692g(a)(2).
The letter listed "Stonecrest Medical Center" only under the heading "Facility," included multiple account numbers (one labeled "Client Account #"), and the detachable payment slip was addressed to Medicredit.
Plaintiff alleged the letter did not explain Medicredit’s relationship to Stonecrest and that the least sophisticated consumer could be misled about who the current creditor is.
Medicredit moved for judgment on the pleadings under Rule 12(c), arguing the notice effectively identified Stonecrest as the creditor.
The court considered only the pleadings and exhibit (the collection letter) and declined to consider materials attached to the response that were not part of the complaint.
The court denied Medicredit’s motion, finding Plaintiff plausibly alleged a §1692g(a)(2) violation because the letter could leave the least sophisticated consumer unsure whether Medicredit or Stonecrest was the creditor.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the collection letter effectively conveys the name of the creditor under §1692g(a)(2)	Letter fails to meaningfully identify the creditor because it only lists "Stonecrest Medical Center" as a "Facility" and does not explain the relationship to Medicredit	Letter sufficiently conveys creditor identity: it states it is a debt-collection attempt, lists Stonecrest under "Facility," and includes account details	Denied motion: complaint plausibly alleges the notice could mislead the least sophisticated consumer about the creditor
Whether the court may consider materials outside the pleadings submitted with the response	N/A (Plaintiff relied on extra-pleading materials in opposition)	Medicredit relied on the pleadings-only record	Court refused to consider materials not attached to the complaint or referenced therein for the 12(c) motion

Hayward v. Cleveland Clinic Found., 759 F.3d 601 (6th Cir. 2014) (Rule 12(c) standard mirrors Rule 12(b)(6) and pleadings are construed in plaintiff’s favor)
Fritz v. Charter Twp. of Comstock, 592 F.3d 718 (6th Cir. 2010) (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading must contain sufficient factual matter to be plausible)
Amini v. Oberlin College, 259 F.3d 493 (6th Cir. 2001) (when documents outside the complaint may be treated as part of the pleadings)
Max Arnold & Sons, LLC v. W.L. Hailey & Co., Inc., 452 F.3d 494 (6th Cir. 2006) (district court may refuse to accept materials outside the pleadings on a Rule 12(c) motion)
Macy v. GC Servs. Ltd. P’ship, 897 F.3d 747 (6th Cir. 2018) (FDCPA purpose and §1692g context)
Fed. Home Loan Mortg. Corp. v. Lamar, 503 F.3d 504 (6th Cir. 2007) (FDCPA objectives and legal standards)
Smith v. Computer Credit, Inc., 167 F.3d 1052 (6th Cir. 1999) (creditor name must be "effectively conveyed" to the least sophisticated consumer)
Stratton v. Portfolio Recovery Assocs., LLC, 770 F.3d 443 (6th Cir. 2014) (use of the least sophisticated consumer standard in FDCPA cases)