August 29, 2014 Case Digest
Posted on August 29, 2014
In Douglass v. Convergent, plaintiff alleged that defendant violated the FDCPA by placing plaintiff's account number on the face of the debt collector's envelope. The district court entered summary judgment in defendant's favor, applying a benign language exception because the account number did not indicate it was a debt collection letter or was otherwise intended to embarrass or humiliate the consumer. Plaintiff appealed, and the appellate court reversed, finding that the disclosure of the account number was prohibited even though it was only visible through an envelope window, and that the inclusion of the account number through the envelope was not benign.