SANDERS v. AMERICAN CORADIUS INTERNATIONAL LLC, 2:22-cv-02652-JXN-CLW

Plaintiff Teanna Sanders sued American Coradius International LLC (ACI) after receiving multiple collection calls in April–May 2021 and an April 8, 2021 collection letter offering $1,664.17 to resolve a USAA account.
Complaint alleged violations of the Fair Debt Collection Practices Act (FDCPA), specifically §§ 1692d, 1692e, and 1692f.
ACI removed the case to federal court and moved to dismiss under Rule 12(b)(6) for failure to state a claim.
The Court evaluated the complaint under Twombly/Iqbal pleading standards and the Third Circuit’s “least sophisticated debtor” objective test for FDCPA claims.
Holding: Court granted ACI’s motion. §1692e claim dismissed with prejudice; §1692d and §1692f claims dismissed without prejudice (leave to amend as to those counts).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the April 8 letter violated §1692e (false/misleading as to who owns the debt)	Letter’s language (ACI “willing to accept $1,664.17”) could be read to mean ACI owns the debt, creating ambiguity for the least sophisticated debtor	Letter clearly names USAA Federal Savings Bank as creditor and ACI as debt collector; offer to accept payment does not imply ownership	Dismissed §1692e; letter not materially confusing; dismissal with prejudice
Whether repeated calls violated §1692d (harassment)	Multiple calls (specific dates) and calls on weekends show harassment/intent to annoy	Allegations are conclusory and do not plead facts showing intent to harass, oppress, or abuse	Dismissed §1692d without prejudice for failure to plead factual allegations of harassing intent
Whether ACI used unfair or unconscionable means in violation of §1692f	Plaintiff alleges unfair means generally based on the calls and letter	No distinct misconduct identified beyond alleged §1692d/§1692e violations; §1692f cannot rest on conduct covered by other FDCPA provisions	Dismissed §1692f without prejudice; no separate unfair conduct pleaded
Pleading sufficiency under Rule 12(b)(6) / least sophisticated debtor standard	Complaint provides facts (calls, letter) sufficient to give fair notice	Allegations are labels/conclusions and the letter’s text defeats the §1692e claim	Complaint fails to state plausible FDCPA claims as pleaded; motion to dismiss granted

Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must state a plausible claim above the speculative level)
Conley v. Gibson, 355 U.S. 41 (1957) (statement of claim must give fair notice)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (court separates conclusory allegations from well-pleaded facts)
Phillips v. County of Allegheny, 515 F.3d 224 (3d Cir. 2008) (pleading standards and inferences for Rule 12(b)(6))
Santiago v. Warminster Twp., 629 F.3d 121 (3d Cir. 2010) (three-part Iqbal/Twombly inquiry applied in Third Circuit)
Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. 573 (2010) (FDCPA prohibits false, deceptive, or unfair practices)
Douglass v. Convergent Outsourcing, 765 F.3d 299 (3d Cir. 2014) (elements to prevail on an FDCPA claim)
Brown v. Card Serv. Ctr., 464 F.3d 450 (3d Cir. 2006) (use of least sophisticated debtor standard)
Tatis v. Allied Interstate, LLC, 882 F.3d 422 (3d Cir. 2018) (least sophisticated debtor preserves reasonableness; must read notices carefully)
Campuzano-Burgos v. Midland Credit Mgmt., Inc., 550 F.3d 294 (3d Cir. 2008) (least sophisticated debtor must read collection notices in their entirety)
Rush v. Portfolio Recovery Assocs., LLC, 977 F. Supp. 2d 414 (D.N.J. 2013) (§1692f is a catch-all and cannot duplicate other FDCPA provisions)
Blair v. Fed. Pac. Credit Co., LLC, 563 F. Supp. 3d 347 (D.N.J. 2021) (discount offer in a collection letter is not necessarily misleading)