Photo of Carter Lawson

On January 21, Colorado Governor Jared S. Polis signed Senate Bill 21-002 into law. This bill modifies the limitations of certain debt collection actions enacted in Senate Bill 20-211, most notably extending the moratorium on extraordinary collection actions from February 1, 2021 to June 1, 2021.

In more detail, Senate Bill 21-002 states that

On January 20, 2021, the Southern District of New York granted Emmanuel Torres’ (“Torres”) motion to remand to state court, holding that Wakefield & Associates’ (“Wakefield”) and Rural Metro Ambulance Corporation’s (“Rural Metro”) argument for removal did not constitute “complete preemption.”

In Torres v. Wakefield & Assocs., Torres filed a complaint in the New

On January 21, 2021, the United States District Court for the Northern District of Illinois granted TransUnion Data Solutions LLC’s (“Trans Union”) motion for judgment on the pleadings, denying Blue Sobenes’ (“Sobenes”) claims against Trans Union under sections 1681i(a) and 1681e(b) of the Fair Credit Reporting Act (“FCRA”).

In Sobenes v. Transunion Data Sols.,

On January 14, 2021, the Court of Common Pleas in Cuyahoga County, Ohio denied a healthcare foundation’s motion to dismiss, ruling that healthcare clinics and hospitals are not “physicians,” as that term is defined in the Ohio Consumer Sales Practices Act, and accordingly, are not exempt from liability resulting from consumer transactions. The case, Brakle

On December 15, 2020, the Seventh Circuit Court of Appeals decided four cases which all dealt with the issue of standing within the context of the Fair Debt Collection Practices Act (“FDCPA”). With these holdings, the Seventh Circuit stated that simply alleging a procedural violation, confusion, or annoyance under the FDCPA does not constitute an

On December 15, 2020, the Board of Commissioners for Polk County, Florida voted to accept an additional $2,812,299.00 of funding from the March 27, 2020, CARES Act (the Act), part of which will be used to provide rental assistance to residents of Polk County. The rental assistance comes in the form of the Polk County

The Eighth Circuit Court of Appeals held that the actions of a debt collector are not necessarily imputed to a debt buyer. This holding reversed the Western District of Arkansas District Court, which held that the actions of the debt collector are necessarily imputed to the debt buyer. The full opinion of Reygadas v. DNF