On March 31, the U.S. District Court for the District of New Jersey granted a debt collector’s motion to dismiss a putative class action alleging violations of the FDCPA, finding that the plaintiff lacked Article III standing. The plaintiff filed suit in March 2018 after receiving a collection letter seeking to recover a $517.14 debt. The letter stated that the amount due may increase because of interest, late charges, and other charges, but the plaintiff alleged that no such interest or charges were ever assessed after the letter was sent. The plaintiff claimed the misleading statements caused uncertainty as to the amount owed and additional interest that would accrue. The parties had entered into a class settlement agreement in August 2019 and later executed an amended settlement agreement, which had received preliminary approval in March 2024. However, while the parties litigated attorney’s fees, the defendant raised the issue of standing for the first time and moved to dismiss in August 2025.

The court held that the plaintiff failed to allege a concrete injury sufficient to establish standing. Citing 3rd Circuit precedent, the court noted that the mere receipt of a misleading statement, or even confusion, without any further consequence, does not confer standing. The court found that the complaint contained no allegations that the plaintiff or other consumers relied on the collection letter or suffered harm as a result of their uncertainty, and that the plaintiff’s suggested injuries — such as consumers forgoing payment of other essential bills or being deterred from disputing the debt — were hypothetical and too speculative to support standing. The court also rejected the plaintiff’s argument that a statutory violation of the FDCPA alone was sufficient, noting that Article III requires a concrete injury even in the context of a statutory violation. The court also rejected the plaintiff’s objection to the timing of the motion, noting that standing is a jurisdictional requirement that cannot be waived and may be raised at any stage of litigation. The complaint was dismissed without prejudice, and the plaintiff was given an opportunity to file an amended complaint.