6th Circuit Rejects ‘Benign Language’ Exception in FDCPA Envelope Disclosure Claim

The U.S. Court of Appeals for the Sixth Circuit recently held that the plain language of 15 U.S.C. 1692f(8), a provision of the Fair Debt Collection Practices Act (FDCPA) regulating what may be shown on an envelope when a debt collector communicates with a consumer by mail, does not include a “benign language” exception.

A copy of the opinion in Donovan v. FirstCredit, Inc. is available at:  Link to Opinion.

A consumer appealed from a judgment entered against her after the district court granted a defendant’s motion for judgment on the pleadings.