Eleventh Circuit Dismisses FDCPA Suit by Consumer Attorney for Lack of Article III Standing

Case Snapshot

• Court: U.S. Court of Appeals for the Eleventh Circuit
• Case: Gregory Light v. LVNV Funding, LLC and Andreu Palma Lavin & Solis, PLLC
• Decision Date: June 3, 2026
• Core Issue: Whether a consumer attorney can establish Article III standing based on harms allegedly arising from debt collection activity directed at a client
• Key Allegation: Attorney Gregory Light alleged FDCPA and FCCPA violations stemming from conduct during a state court collection action against his client
• Court Holding: The attorney failed to allege a concrete injury in fact sufficient to establish Article III standing
• Outcome: Appeal dismissed for lack of jurisdiction
• Notable Detail: The court held that time spent correcting a client’s legal problem and alleged professional embarrassment were derivative injuries that could not support standing

The U.S. Court of Appeals for the Eleventh Circuit has dismissed a Fair Debt Collection Practices Act (FDCPA) lawsuit brought by a Florida attorney, holding that the attorney lacked Article III standing because the alleged harms stemmed from injuries suffered by his client rather than himself.

In a published opinion issued June 3, the court concluded that attorney Gregory Light failed to allege a concrete injury in fact, a constitutional requirement necessary for federal courts to exercise jurisdiction. The ruling reinforces the Eleventh Circuit’s recent trend of closely scrutinizing standing in FDCPA litigation and may limit future claims brought by attorneys or other third parties whose alleged injuries arise from collection activity directed at consumers.

Dispute Stemmed From Collection Action Against Client

The case originated from a state court debt collection lawsuit filed by LVNV Funding, LLC against consumer Franklyn Rodriguez.

According to the court’s opinion, Light was retained to represent Rodriguez shortly before a scheduled pretrial conference. Light alleged that counsel for LVNV indicated a settlement had been reached and represented that the court would be informed of the agreement. Based on those representations, Light did not attend the conference.

The state court subsequently entered a default against Rodriguez and later entered a default final judgment. Light alleged that LVNV and its law firm, Andreu Palma Lavin & Solis, PLLC, made misleading representations regarding the status of the settlement and the default proceedings.

After the judgment was entered, Light spent several hours preparing a motion to vacate the judgment on behalf of his client. The judgment and default were eventually set aside in state court.

Light later filed suit in federal court under both the FDCPA and the Florida Consumer Collection Practices Act (FCCPA), alleging that the defendants’ conduct caused him personal distress, embarrassment, reputational harm and loss of time.

Court Focuses on Constitutional Standing

Rather than addressing whether the alleged conduct violated the FDCPA, the Eleventh Circuit focused on the threshold issue of standing.

The court emphasized that federal courts must first determine whether a plaintiff has suffered a concrete and particularized injury before considering whether a statute authorizes the plaintiff to sue.

The opinion drew heavily from recent standing decisions, including TransUnion LLC v. Ramirez, Spokeo, Inc. v. Robins, Hunstein v. Preferred Collection & Management Services, Inc., and Nelson v. Experian Information Solutions, Inc.

The panel reiterated that a statutory violation alone does not automatically satisfy Article III’s injury requirement.

“An injury in law is not an injury in fact,” the court explained while discussing prior standing precedent.

The court found that every harm alleged by Light ultimately traced back to the default judgment entered against Rodriguez, not against Light himself.

“The default judgment entered in the state-court debt-collection proceeding was entered against Rodriguez,” the court wrote. “The time Light spent was spent remedying the adverse result Rodriguez received, and the distress Light experienced arose from his client’s legal predicament.”

Derivative Injuries Insufficient

A key aspect of the decision involved the court’s distinction between direct injuries and derivative injuries.

The panel concluded that Light’s claimed emotional distress and professional inconvenience were consequences of his client’s situation rather than independent injuries to himself.

The court also rejected the argument that the time spent preparing a motion to vacate the judgment could establish standing.

Citing its 2025 decision in Nelson v. Experian Information Solutions, Inc., the court reaffirmed that plaintiffs cannot create standing simply by spending time or money responding to an alleged statutory violation.

According to the court, Light’s efforts were directed toward correcting a legal problem affecting his client, not himself.

Reputational Harm Theory Also Rejected

The court separately examined Light’s argument that he suffered reputational harm.

While acknowledging that reputational injury can constitute a concrete injury under Article III in certain circumstances, the court found the allegations insufficient.

The opinion noted that the alleged misrepresentations concerned Rodriguez’s debt and the status of the collection proceedings, not Light personally. The court also found no allegations that any false statements about Light had been communicated to third parties.

The only reputational injury identified by Light involved an uncomfortable conversation with his client regarding the default judgment.

According to the court, that private attorney-client discussion did not resemble the type of publicized reputational harm traditionally recognized through defamation claims.

The court further noted that Light did not allege lost clients, lost revenue, sanctions, or damage to his standing within the legal community.

Why It Matters

The ruling provides another significant standing decision within the Eleventh Circuit’s FDCPA jurisprudence.

For debt collectors, collection law firms, and compliance professionals, the opinion reinforces that Article III standing remains a powerful threshold defense in federal consumer protection litigation.

The decision may be particularly important in cases involving non-consumer plaintiffs, including attorneys, representatives, family members, or other individuals who claim harm arising from collection activity directed at someone else.

The court’s analysis also strengthens the growing body of precedent requiring plaintiffs alleging reputational injuries to identify a concrete harm that closely resembles traditional defamation, including communication of false information to third parties.

Perhaps most significantly, the decision underscores that federal courts will continue to distinguish between statutory violations and constitutionally sufficient injuries, even where Congress has authorized broad categories of individuals to bring suit under consumer protection laws.