Markakos v. Medicredit, Inc., No. 20-2351 (7th Cir. 2021)Annotate this Case
Medicredit sent Markakos a letter seeking to collect $1,830.56 on behalf of a creditor identified as “Northwest Community 2NDS” for medical services. Markakos’s lawyer sent Medicredit a letter disputing the debt (because the medical services were allegedly inadequate). Medicredit then sent a response that listed a different amount owed: $407.00. Markakos sued Medicredit for allegedly violating the Fair Debt Collection Practices Act, 15 U.S.C. 1692g(a)(1)–(2), by sending letters to her that stated inconsistent debt amounts and that unclearly identified her creditor as “Northwest Community 2NDS”—which is not the name of any legal entity in Illinois.
The Seventh Circuit affirmed the dismissal of the case without prejudice. Markakos lacks standing to sue Medicredit under the Act because she did not allege that the deficient information harmed her in any way. She admits that she properly disputed her debt and never overpaid. Markakos’s only other alleged injury is that she was confused and aggravated by Medicredit’s letter. Winning or losing this suit would not change Markakos’s prospects; if Markakos lost, she would continue disputing her debt based on the inadequacy of the services and if she won, she would do the same. Not a penny would change hands, and no word or deed would be rescinded.