Pucillo v. National Credit Systems, Inc., No. 21-3131 (7th Cir. 2023)
Annotate this Case
Pucillo, an Indiana resident who formerly used the last name Lock, had previously leased an apartment from Main Street. He filed for Chapter 7 bankruptcy in May 201, and listed as a debt past‐due rent he allegedly owed Main. The bankruptcy court granted him a discharge in September 2017, including any debt to Main. That bankruptcy discharge is listed on Pucillo’s credit reports but Main was not notified of Pucillo’s bankruptcy. In July 2017, 10 weeks before the discharge, Main had placed Pucillo’s account with National Credit for collection. Over the next 18 months, National sent Pucillo two collection letters, stating that if payment was made, National “will update credit data it may have previously submitted regarding this debt.”
The week before Pucillo received the second letter, he filed suit under the Fair Debt Collection Practices Act, 15 U.S.C. 1692e (demanding payment of a debt not owed) and section 1692c(c) (failure to cease communications and cease collections). He alleged that National’s continued communications “confused and alarmed” him. National did not actually give information to a credit reporting agency—before or after his bankruptcy discharge. The Seventh Circuit affirmed the dismissal of the suit. Pucillo lacked Article III standing to sue. Pucillo’s allegations of ʺconfusion,” “stress,” “concern,” and “fear” are not sufficiently concrete to result in an injury in fact that would give him standing to sue.
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.