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Hunsteinv.Preferred Collection & Management Services, Inc.

CourtUnited States Court of Appeals for the Eleventh Circuit
Docket No.19-14434
DecidedSeptember 8, 2022
Reporter48 F.4th 1236 (11th Cir. 2022)
JudgesEleventh Circuit panel; see published opinion.
Tags
CivilConsumer ProtectionFair Debt Collection Practices ActArticle III StandingData DisclosureVendor CommunicationsEn BancDismissal Without Prejudice
Case Summary

A debt collector sent a consumer’s account information to its mail vendor so the vendor could print and mail a collection letter. On rehearing en banc, the Eleventh Circuit held that the alleged disclosure violated the Fair Debt Collection Practices Act but did not itself create the concrete, historically comparable privacy harm required for Article III standing: the information was shared privately, not publicized. The court vacated the judgment and remanded for dismissal without prejudice.

Opinion

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Hunstein v. Preferred Collection & Management Services, Inc. — The Atlanta Gleaner