In Magdy v. I.C. Sys., Inc., No. 21-3010, 2022 WL 4075764, at *1 (8th Cir. Sept. 6, 2022), the Eighth Circuit Court of Appeals, faced with a matter of first impression, held that a non-consumer attorney could not bring an FDCPA claim.
The facts of the case are straightforward. On July 27, 2020, Andrew Madgy (“Madgy”), a bankruptcy attorney, received a debt collection letter from I.C. System, Inc. (“ICS”). The letter identified Madgy as the attorney for a consumer named in the letter. The only problem – Madgy was not the consumer’s lawyer and the consumer had neither ...