Yet another FDCPA case met its demise in Florida thanks to the 11th Circuit’s Trichell decision. As you may recall, Trichell held that a plaintiff lacks standing to bring an FDCPA case unless he shows how he himself was harmed by the allegedly violative practices. Grandstanding about potential harm simply won’t do. In short? No harm, no foul.

The progeny of Trichell keep coming. Last week, we talked about the Cooper case, where the 11th Cir. found that a consumer doesn’t have standing to bring an overshadowing claim if she didn’t intend to dispute the debt or accept any of the payment options provided. The week prior, we discussed Daniels, where M.D. Georgia found that plaintiff lacked standing because he failed to allege how he was actually harmed from a litigation notice that did not include internally-referenced courtesy enclosures.

This week in the Hill decision, S.D. Fla. dismissed an FDCPA claim—alleging that a bankruptcy proof of claim that listed the amount owed “in principal only” was misleading—because the consumer failed to allege any kind of injury to himself. An allegation that unsophisticated consumers might have to use resources to object to the proof of claim did not suffice. And, like in Trichell, the risk of harm was gone by the time the FDCPA suit was filed.

Yowza, this thing is catching on like wildfire.

Have a great week!