Two Judges Question whether the 7th Circuit has Gone Too Far in Standing Decisions

The Seventh Circuit Court of Appeals has been quite clear in its recent holdings regarding Article III standing in FDCPA cases: to have standing a consumer must do more than allege an FDCPA violation.  However, on May 14, 2021, in the case of Markakos v. Mericredit, Inc., No. 20-2351, (7th Cir May 14, 2021), although the 7^th Circuit reached a similar conclusion, two of the judges on the panel issued concurring opinions which agreed with the result, but questioned whether the 7^th Circuit has gone too far.

The Case:

In Markakos, the consumer filed a lawsuit against a debt collector, alleging that the debt collector sent her letters with inconsistent amounts and which did not clearly identify the creditor. Notably, however, the consumer admitted she properly disputed the debt and did not overpay.  Instead, she alleged she was injured because she was confused and aggravated by the letters.