Gulley v. Markov & Krasny , No. 11-2104 (7th Cir. 2011)
Annotate this CaseIn 2008 the city levied fines against plaintiff, arising from a parcel of real estate that he no longer owned. When he did not pay those fines, the city retained defendant to collect. The district court dismissed his suit under the Fair Debt Collection Practices Act, 15 U.S.C. 1692-1692p, finding that fines are not "debts" covered by the FDCPA. For purposes of the statute, a "debt" can arise only from a "transaction in which money, property, insurance, or services which are the subject of the transaction are primarily for personal, family, or household purposes." The Seventh Circuit affirmed, stating that fines cannot reasonably be understood as debts arising from consensual consumer transactions for goods and services.
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