David Schultz Reviews a Humorous—But Important—FDCPA Procedural Ruling
Featured Column in the August 10, 2026, Issue of the ARM Compliance Digest
In The News | 1 min read
Aug 24, 2026
In the August 10, 2026, issue of the AccountsRecovery.net ARM Compliance Digest, Hinshaw partner David Schultz recommends the entertainment value of reading a 28-page decision by District Judge Seeger denying a motion for default judgment in a case brought under the Fair Debt Collection Practices Act.
David writes:
We’re generally too busy to read cases for fun. However, if you have a chance, you’ll get a kick out of N.D. IL Judge Seeger’s ruling in Love v Travelers Management Group, et al. He essentially writes a 28 page law review article on a relatively straightforward legal issue but does so with humor. In the process, he explains it “isn’t common for the leading case on a procedural question to come from the Reconstruction era” – Frow v. De La Vega, 82 U.S. 552, 554 (1872).
If you want the holding, you could probably just skip to the last page. Even the judge says he rambled on: “All of this is a long way of making a simple point.” That simple point is that the court “needs to sit tight on entering a default judgment against the agent until this Court has resolved the claims against the principal on the merits.”
He explains that when the liability of co-defendants is mutually dependent, multiple judgments create a potential for inconsistencies. He elaborates on this point: “Joint liability is like being on a ship with a bunch of friends, and hitting an iceberg in the North Atlantic. It’s sink-or-float time, for everyone. You’re going to stay afloat as a group, or you’re all going down together. Everyone is in the same boat, literally and figuratively.”
It’s not a particularly complex legal issue but Judge Seeger surely makes it a fun story.
-
- AccountsRecovery.net ARM Compliance Digest: “Judge Invokes 154-Year-Old Precedent to Deny Default Judgment in FDCPA Case” (August 10, 2026)
Related People
Related Capabilities
Related Locations
Featured Insights

In The News
Aug 24, 2026
David Schultz Reviews a Humorous—But Important—FDCPA Procedural Ruling

Press Release
Aug 20, 2026
115 Hinshaw Lawyers Recognized in 2027 Editions of The Best Lawyers in America® and Ones to Watch®

Press Release
Aug 20, 2026
Hinshaw’s Landmark Tower Client Project Receives 2026 Top Projects Award

Press Release
Aug 19, 2026
Fernando Rivera-Maissonet Elected as HNBA Region II Governor and Board of Governors Member

Employment Law Observer
Aug 17, 2026
Massachusetts’ First Paid Family Medical Leave Act Verdict Yields $4.75 Million Award

Press Release
Aug 13, 2026
Lauren Campisi Recognized as a 2026 BTI Client Service All-Star by BTI Consulting Group

Consumer Crossroads: Where Financial Services and Litigation Intersect
Aug 13, 2026
How Will Banks Be Impacted by the Proposed Regulation O Amendments?

Press Release
Aug 12, 2026
William Cook Honored With the Distinguished Service Award by the Chicago Bar Association

Webinar
Aug 12, 2026
John Ryan Presents on "Understanding what is Covered Under the TCPA Today"

In The News
Aug 12, 2026
Scott Seaman Analyzes California’s New Pleading Standards for Excess Insurance Policy Claims



