7th Cir.: Settlement of Claim with Creditor May Mean Dismissal of Claim Against Collector

Last week, insideARM published an article about a Northern District of Illinois case that barred a plaintiff's attempt at claim splitting where a Fair Debt Collection Practices Act (FDCPA) claim involved two separate accounts but arose from the same set of facts against the same defendant. The issue of claim splitting came up again in the midwest, this time before the Seventh Circuit Court of Appeals.

On August 13, 2018, the opinion in Portalatin v. Blatt, Hasenmiller, Leibsker & Moore, LLC, Nos. 16-1578 and 17-3335 (7th Cir. Aug. 13, 2018) found that a plaintiff cannot recover for the same FDCPA claim against two separate defendants.

Factual and Procedural Background

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