District Court (Cal.) Finds Disclaimer of No Attorney Review in Collection Letter Negates “Absence of Meaningful Involvement” Claim

In Walsh v. Hannah & Assoc., here, Judge Burrell of the USDC for the Eastern District of California found that an attorney disclaimer in a collection letter that no attorney had reviewed the file negated a claim that the letter was a ‘false representation or implication that . . .any communication was from an attorney” under 15 U.S.C. 1692(e)(5).  The District Court relied on persuasive authority from the Court of Appeals for the Second Circuit in Greco v. Trauner, Cohen, and Thomas, LLP. 412 F.3d 360, 365 (2d Cir. 2005).