Thomas v. LVNV Funding, LLC

Plaintiff filed a lawsuit under the Fair Debt Collection Practices Act, alleging that she was entitled to statutory damages where there was a delay between when she disputed the accuracy of a debt and when defendant reported the dispute to credit-reporting agencies. A jury found in favor of the plaintiff and awarded her damages. On appeal, defendant did not contest the district court’s conclusion that defendant was required to notify the credit-reporting agency earlier, but rather argued that the delay did not injure the plaintiff and that without an injury she lacked standing to file a lawsuit. The Seventh Circuit agreed and reversed, explaining that the availability of statutory damages does not suffice for standing and there must be some injury whether it is financial or reputational. (SYKES and PRYOR, concurring)