On August 25, 2016, the Fourth Circuit held in In re Eric Dubois, Case No. 15-1945, that filing a proof of claim based on a time-bared debt in a Chapter 13 bankruptcy does not violate the Fair Debt Collection Protection Act (FDCPA) when the applicable state statute of limitations does not extinguish the debt. This decision rejects the reasoning of the Eleventh Circuit in multiple opinions and widens the circuit split created by an Eight Circuit decision in July 2016 and a Seventh Circuit decision in August 2016.