Sixth Circuit holds that bare allegation of FDCPA statutory violation is not an Article III injury under Spokeo

In today's decision in Hagy v. Demers & Adams, the Sixth Circuit held that a bare allegation that a debt collector's letter that fails to say it's "from a debt collector" as required by the Fair Debt Collection Practices Act, 15 U.S.C. § 1692e(11), is not an article III injury under the Supreme Court's decision in Spokeo v. Robins.

Judge Jeffrey Sutton says that, in ditching the case, he's rejecting the "anything-hurts-so-long-as-Congress-says-it-hurts" theory of article III injury. 

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