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North American Credit Services, Inc. v. Abdul Crawford

Paid petition · United States Court of Appeals for the Eleventh Circuit, No. 24-13931 · judgment July 1, 2025


Certiorari denied · November 17, 2025
Pre-decision estimate: 2% cert probability

Before the decision, well below the 4.1% base rate, with no standout signals pointing toward a grant.

Questions presented

The questions presented are:

  1. Whether the FDCPA requires third party debt collectors to conduct an independent preemptive investigation to review for all potential defects or challenges to the debt, including its legal status, before mailing the 1692g notice of validation, irrespective of any reasonable reliance upon the creditor’s representations?

  2. Whether the FDCPA’s bona fide error defense is limited only to the third party debt collector’s own internal policies and procedures, and excludes any development of pre-placement procedures with the original creditor to avoid violations?

  3. Whether a medical debt incurred during the course and scope of the patient’s employment and subject to Florida’s Worker’s Compensation Act, is not considered a consumer debt under the FDCPA?

Counsel of record

For petitioner
Ernest Henry Kohlmyer III
Zimmerman, Kiser & Sutcliffe, P.A.

For respondent
Scott D. Owens
Scott D. Owens, PA

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Proceedings

  1. Nov 17 2025
    Motion to substitute Lisa J. Crawford, authorized representative, as respondent in place of Abdul Crawford, Deceased GRANTED.
  2. Nov 17 2025
    Petition DENIED.
  3. Oct 29 2025
    DISTRIBUTED for Conference of 11/14/2025.
  4. Oct 29 2025
    Brief amicus curiae of ACA International filed. (Distributed)
  5. Oct 21 2025
    Motion to substitute Lisa J. Crawford, authorized representative, as respondent in place of Abdul Crawford, Deceased filed by counsel for respondent.
  6. Oct 09 2025
    Waiver of right of respondent Abdul Crawford to respond filed.
  7. Sep 26 2025
    Petition for a writ of certiorari filed. (Response due October 30, 2025)