15 U.S.C. § 1692i

Legal actions by debt collectors

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(a) VenueAny debt collector who brings any legal action on a debt against any consumer shall—(1) in the case of an action to enforce an interest in real property securing the consumer’s obligation, bring such action only in a judicial district or similar legal entity in which such real property is located; or(2) in the case of an action not described in paragraph (1), bring such action only in the judicial district or similar legal entity—(A) in which such consumer signed the contract sued upon; or(B) in which such consumer resides at the commencement of the action.(b) Authorization of actions

Nothing in this subchapter shall be construed to authorize the bringing of legal actions by debt collectors.

(Pub. L. 90–321, title VIII, § 811, as added Pub. L. 95–109, Sept. 20, 1977, 91 Stat. 880.)Statutory Notes and Related SubsidiariesEffective Date

Section effective upon the expiration of six months after Sept. 20, 1977, see section 819 of Pub. L. 90–321, as added by Pub. L. 95–109, set out as a note under section 1692 of this title.

Notes of Decisions

Cited in 172 cases (39 in the last 5 years), 1980–2025 · leading case: Greg Hageman v. Dennis Barton, III, 817 F.3d 611 (8th Cir. 2016).

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Greg Hageman v. Dennis Barton, III, 817 F.3d 611 (8th Cir. 2016). · cites it 5× “15 U.S.C. § 1692i. Finally, he alleged Barton attempted to “collect amounts that Plaintiff never owed including an inflated principal balance, inflated and illusory interest charges, and inflated and.”

Mark Suesz v. Med-1 Solutions, LLC, 757 F.3d 636 (7th Cir. 2014). · cites it 7× “15 U.S.C. § 1692i. This appeal requires us to apply this statutory language to the 2 No.”

Oliva v. Blatt, Hasenmiller, Leibsker & Moore LLC, 864 F.3d 492 (7th Cir. 2017). · cites it 8× “15‐2516 Debt Collection Practices Act, a debt collector who sues to col‐ lect a consumer debt must sue in the “judicial district or sim‐ ilar legal entity” where the debtor lives or signed the contract in question.”

Elizarov v. Equity Experts LLC, 312 F. Supp. 3d 624 (E.D. Mich. 2018). · cites it 16× “Second, the record establishes that Defendant's choice of forum for the collection action was permissible under 15 U.S.C. § 1692i, which, depending on the nature of the debt sued upon, requires a debt collector to bring a collection action against a consumer only in the…”

Jackson v. Blitt & Gaines, P.C., 833 F.3d 860 (7th Cir. 2016). · cites it 4× “Plaintiffs have filed their complaints pursuant to this provision, which provides in relevant part that “[a]ny debt collector who brings any legal action on a debt against any consumer shall .”

Obduskey v. McCarthy & Holthus LLP, 139 S. Ct. 1029 (2019). · cites it 2× “Second, Obduskey points to the Act’s venue provision, 15 U. S. C. §1692i(a), which states that “[a]ny debt collec- tor who brings any legal action on a debt against any consumer shall .”

Bryson Ray v. McCullough Payne & Haan, LLC, 838 F.3d 1107 (11th Cir. 2016). · cites it 5× “The statute required the judgment-creditor to file the collection action in the county in which the trustee or employer (not the consumer) was located, and the rules required the judgment creditor to direct the summons to the trustee or employer (not the consumer) and required…”

Vien-Phuong Thi Ho v. ReconTrust Co., 858 F.3d 568 (9th Cir. 2016). · cites it 2× “In particular, the Senate Report on the FDCPA noted that “the committee does not intend the definition to cover ... the collection of debts, such as mortgages and student loans, by persons who originated such loans.”

Rolando Serna v. Law Off. of Joseph Onwuteaka, e, 732 F.3d 440 (5th Cir. 2013). · cites it 5× “SMITH, Circuit Judge, dissenting: In the majority’s view, to “bring such action,” 15 U.S.C. § 1692i(a)(2), refers to something different from “[a]n action .”

Alaska Tr., LLC v. Ambridge, 372 P.3d 207 (Alaska 2016). · cites it 4× “31 15 U.S.C. § 1692i(a)(1) (2012); see also S.”

Harrington v. Cacv of Colorado, LLC, 508 F. Supp. 2d 128 (D. Mass. 2007). · cites it 5× “In substance, Defendants clearly violated 15 U.S.C. § 1692i, which provides: any debt collector who brings any legal action on a debt against any consumer shall .”

Lawrence Glazer v. Chase Home Fin., LLC, 704 F.3d 453 (6th Cir. 2013). · cites it 2× “Consider also § 1692L This section requires a debt collector bringing a legal action against a consumer “to enforce an interest in real property securing the consumer’s obligation” — e.”

Show all 172 citing cases →

— 15 U.S.C. § 1692i(2) — 2 cases

McKnight v. Benitez, 176 F. Supp. 2d 1301 (M.D. Fla. 2001).

Samara Portfolio Mgmt., LLC & Joseph Onwuteaka v. Neda Zargari (Tex. App. 2018).

— 15 U.S.C. § 1692i(2)(A) — 1 case

in Re Christopher Morice (Tex. App. 2011).

— 15 U.S.C. § 1692i(a) — 31 cases

Obduskey v. McCarthy & Holthus LLP, 139 S. Ct. 1029 (2019). “Second, Obduskey points to the Act’s venue provision, 15 U. S. C. §1692i(a), which states that “[a]ny debt collec- tor who brings any legal action on a debt against any consumer shall .”

Bryson Ray v. McCullough Payne & Haan, LLC, 838 F.3d 1107 (11th Cir. 2016). “The statute required the judgment-creditor to file the collection action in the county in which the trustee or employer (not the consumer) was located, and the rules required the judgment creditor to direct the summons to the trustee or employer (not the consumer) and required…”

Greg Hageman v. Dennis Barton, III, 817 F.3d 611 (8th Cir. 2016). “15 U.S.C. § 1692i. Finally, he alleged Barton attempted to “collect amounts that Plaintiff never owed including an inflated principal balance, inflated and illusory interest charges, and inflated and.”

Oliva v. Blatt, Hasenmiller, Leibsker & Moore LLC, 864 F.3d 492 (7th Cir. 2017). “15‐2516 Debt Collection Practices Act, a debt collector who sues to col‐ lect a consumer debt must sue in the “judicial district or sim‐ ilar legal entity” where the debtor lives or signed the contract in question.”

Oei v. N. Star Capital Acquisitions, LLC, 486 F. Supp. 2d 1089 (C.D. Cal. 2006).

— 15 U.S.C. § 1692i(a)(1) — 8 cases

Alaska Tr., LLC v. Ambridge, 372 P.3d 207 (Alaska 2016). “31 15 U.S.C. § 1692i(a)(1) (2012); see also S.”

Cohen v. Rosicki, Rosicki & Assocs., P.C., 897 F.3d 75 (2d Cir. 2018).

Vien-Phuong Thi Ho v. ReconTrust Co., 858 F.3d 568 (9th Cir. 2016). “In particular, the Senate Report on the FDCPA noted that “the committee does not intend the definition to cover ... the collection of debts, such as mortgages and student loans, by persons who originated such loans.”

Elizarov v. Equity Experts LLC, 312 F. Supp. 3d 624 (E.D. Mich. 2018). “Second, the record establishes that Defendant's choice of forum for the collection action was permissible under 15 U.S.C. § 1692i, which, depending on the nature of the debt sued upon, requires a debt collector to bring a collection action against a consumer only in the…”

Timothy Barnes v. Routh Crabtree Olsen Pc, 963 F.3d 993 (9th Cir. 2020).

— 15 U.S.C. § 1692i(a)(2) — 48 cases

Rolando Serna v. Law Off. of Joseph Onwuteaka, e, 732 F.3d 440 (5th Cir. 2013). “SMITH, Circuit Judge, dissenting: In the majority’s view, to “bring such action,” 15 U.S.C. § 1692i(a)(2), refers to something different from “[a]n action .”

Jackson v. Blitt & Gaines, P.C., 833 F.3d 860 (7th Cir. 2016). “Plaintiffs have filed their complaints pursuant to this provision, which provides in relevant part that “[a]ny debt collector who brings any legal action on a debt against any consumer shall .”

Prof'l Collection Consultants v. Lauron, 8 Cal. App. 5th 958 (Cal. Ct. App. 2017).

Mark Suesz v. Med-1 Solutions, LLC, 757 F.3d 636 (7th Cir. 2014). “15 U.S.C. § 1692i. This appeal requires us to apply this statutory language to the 2 No.”

— 15 U.S.C. § 1692i(a)(2)(A) — 7 cases

Dawn M. Newsom, on Behalf of Herself & All Others Similarly Situated v. Lawrence Friedman, 76 F.3d 813 (7th Cir. 1996).

Davis v. Avco Fin. (In Re Davis), 158 B.R. 1000 (Bankr. N.D. Ind. 1993).

Maxwell v. Adams (E.D. Ark. 2021).

Neal v. Adams (E.D. Ark. 2021).

— 15 U.S.C. § 1692i(a)(2)(B) — 10 cases

Hess v. Cohen & Slamowitz, LLP, 637 F.3d 117 (2d Cir. 2011).

Jacobson v. Knepper & Moga, P.C., 706 N.E.2d 491 (Ill. 1998).

Unifund Ccr Partners v. Sunde, 260 P.3d 915 (Wash. Ct. App. 2011).

A1 Heating & Cooling, Inc. v. Thomas, 2024 Ohio 109 (Ohio Ct. App. 2024).

— 15 U.S.C. § 1692i(a)(l) — 6 cases

Lawrence Glazer v. Chase Home Fin., LLC, 704 F.3d 453 (6th Cir. 2013). “Consider also § 1692L This section requires a debt collector bringing a legal action against a consumer “to enforce an interest in real property securing the consumer’s obligation” — e.”

Kaltenbach v. Richards, 464 F.3d 524 (5th Cir. 2006).

Obduskey v. Wells Fargo, 879 F.3d 1216 (10th Cir. 2018).

Vien-Phuong Thi Ho v. Recontrust Co., 840 F.3d 618 (9th Cir. 2016).

Maynard v. Cannon, 650 F. Supp. 2d 1138 (D. Utah 2008).

— 15 U.S.C. § 1692i(b) — 5 cases

Patricia Arellano v. Clark Cnty. Collection Serv., 875 F.3d 1213 (9th Cir. 2017).

Kolker v. Duke City Collection Agency, 750 F. Supp. 468 (D.N.M. 1990).

Deitemyer v. Ryback, Esq. (D. Maryland 2019).

Grooms v. Sklar Law, LLC (E.D. Pa. 2023).

— 15 U.S.C. § 1692i(d) — 3 cases

Johnson v. NCB Collection Servs., 799 F. Supp. 1298 (D. Conn. 1992).

Nix v. Welch & White, P.A., 55 F. App'x 71 (3rd Cir. 2003).

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