United States v. Bedi, 15 F.4th 222

Datalink Computer Products, Inc. and its president Vickram Bedi hired Helga Ingvarsdóttir on an H‑1B and certified to DOL they would pay the prevailing wage.
Ingvarsdóttir alleged she was paid little or nothing; DOL found unpaid H‑1B wages and an ALJ (and later the ARB) ordered Bedi and Datalink to pay about $341,000 in back wages to Ingvarsdóttir.
Bedi and Datalink failed to pay; Ingvarsdóttir’s state‑court attempt to collect was dismissed.
The United States sued under the Federal Debt Collection Procedures Act (FDCPA), seeking to use FDCPA procedures to collect the administrative back‑wage award.
The district court granted summary judgment for the Government relying on Second Circuit precedent in NLRB v. E.D.P.; on appeal the Second Circuit reversed, holding the FDCPA does not authorize collection of back wages owed to a private employee and overruling E.D.P.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the FDCPA authorizes the United States to collect an administrative award of back wages owed to a private employee	FDCPA applies because the award enforces federal labor standards, advances public interest, and the debt derives from federal regulation (not a purely private contract)	The award is owed to the private employee (Ingvarsdóttir), not the United States; FDCPA applies only to amounts "owing to the United States"	Reversed: FDCPA applies only to amounts "owing to the United States." An administrative back‑wage award payable to a private person is not a FDCPA "debt." E.D.P. overruled
Whether the district court erred in rejecting defendants’ in pari delicto defense	(Gov’t did not press a contrary position on appeal)	Defendants argued in pari delicto could bar enforcement	Not reached: the court declined to decide because statutory interpretation resolved the case

NLRB v. E.D.P. Medical Computer Sys., Inc., 6 F.3d 951 (2d Cir. 1993) (previous Second Circuit decision permitting FDCPA collection of agency back‑pay awards; overruled)
Nathanson v. NLRB, 344 U.S. 25 (1952) (NLRB backpay is not a debt "owing to the United States" for Bankruptcy Act priority purposes)
United States v. Bongiorno, 106 F.3d 1027 (1st Cir. 1997) (FDCPA does not apply where government is not holder or direct beneficiary of the debt)
Sobranes Recovery Pool I, LLC v. Todd & Hughes Constr. Corp., 509 F.3d 216 (5th Cir. 2007) (interpreting FDCPA limitation on debts arising from contracts to exclude private‑origin obligations)
Bostock v. Clayton County, 140 S. Ct. 1731 (2020) (statutory‑interpretation principles cited regarding adherence to text)