Buchanan v. Northland Grp., Inc., No. 13-2523 (6th Cir. 2015)
Annotate this CaseLVNV buys uncollectable debts at a discount and pays Northland Group to collect them. LVNV purchased a debt of Buchanan’s and assigned it to Northland for collection. Northland sent Buchanan a letter, proposing to “settle” the balance of $4,768.43 for a payment of $1,668.96. The letter did not disclose that the Michigan six-year statute of limitations had run on the debt or that a partial payment on a time-barred debt restarts the statute-of-limitations clock under Michigan law. Buchanan alleged that the letter falsely implied that Northland held a legally enforceable obligation. Buchanan filed a purported class action under the Fair Debt Collection Practices Act, 15 U.S.C. 1692–1692p.The district court rejected Buchanan’s discovery request and dismissed, concluding that Northland’s letter was not misleading as a matter of law. The Sixth Circuit reversed, reasoning that the term “settlement” is one of “equivocal meaning” and that an unsophisticated debtor who cannot afford the settlement offer might nevertheless assume from the letter that some payment is better than no payment.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.