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Romea v. Heiberger & Assoc.
163 F.3d 111 (2d Cir. 1998). ; Clearinghouse Number: 52257
Description
Three-Day Notice to Pay Overdue Rent or Face Summary Eviction Violated Fair Debt Collection Practices Act
Abstract
The Second Circuit held that the Fair Debt Collections Practices
Act (FDCPA) applied to an attorney’s execution and delivery
of the three-day rent demand notice required by New York state law
as a condition for a summary eviction proceeding.
Defendant—landlord’s attorney—notified tenant
that, unless she tendered $2,800 in past-due rent within three days
of the date of the notice, landlord would commence summary eviction
proceedings against her. Tenant alleged that the three-day notice
violated 15 U.S.C. § 1692(g) because the notice failed to
advise and give her 30 days within which to dispute the debt.
Tenant also claimed that, in violation of 15 U.S.C. §
1692(e)(11), the notice failed to disclose clearly that defendant
was attempting to collect a debt and, in violation of 15 U.S.C.
§ 1692(e)(5), threatened action that could not legally be
taken. Moving to dismiss, defendant argued that FDCPA did not apply
to the notice because rent due was not a "debt" and the
notice was not a debt collection "communication" within
the meaning of the Act. The district court denied defendant’s
motion, and defendant appealed. Affirming, the court of appeals
held that back rent was a debt within the meaning of FDCPA. The
court rejected defendant’s argument that rent did not
constitute a debt because it did not arise out of an extension of
credit. Noting that back rent was an obligation that arose only
from the tenant’s failure to pay the amounts due under the
contractual lease transaction, the court found that back rent was
analogous to the obligations arising out of a dishonored check. The
court also rejected the argument that back rent was not a debt
because, by definition, tenants who owed back rent breached their
lease and thereby terminated it. In New York a tenant’s
failure to make a rental payment did not automatically end the
lease agreement. The court also found that the three-day notice was
a "communication" to collect a debt; that the letter also
served as a prerequisite to commencement of summary eviction
proceedings was wholly irrelevant to FDCPA requirements and
applicability; and 15 U.S.C. § 1692a(6)(D), which exempts
persons attempting to serve legal process from the definition of
"debt collector," did not apply to attorneys sending
three-day notices to pay back rent or be evicted.
