Zero Means Zero
To reach the result required three appellate judges, one trial judge and several lawyers. At the end, however, zero was emphatically held to mean zero as a matter of federal law.
April 25, 2021 at 10:00 AM
1 minute read
In a 10-page precedential decision, a Third Circuit panel unanimously held that zero equals zero, affirming the decision of the District of New Jersey. Hopkins v. Collecto (April 12, 2021).
The case arose under the federal Fair Debt Collection Practices Act. Because the debt in question carried no interest, the collection letter, in tabular form, reflected accrued interest as "$0.00". Plaintiff debtor, asserting a class action, alleged that the collection letter, by showing that zero interest was owed, falsely implied that interest could accrue later.
Applying the circuit's "least sophisticated consumer" standard, the circuit court affirmed the district court's dismissal of the class action complaint. To reach the result required three appellate judges, one trial judge and several lawyers. At the end, however, zero was emphatically held to mean zero as a matter of federal law.
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