The Eighth Circuit held that a debt collector’s failure to report to a credit reporting agency that the borrower disputed the debt at issue did not constitute a false, deceptive, or misleading communication in violation of the FDCPA. The unsophisticated consumer standard was reviewed by the court and determined that it did not apply since the notice was not to the consumer but consumer reporting agency. Hemmingsen v. Messerli & Kramer, P.A., 674 F.3d 814, 819 (8th Cir. 2012); Peters v. Gen. Serv. Bureau, Inc., 277 F.3d 1051, 1055 (8th Cir. 2002).
http://media.ca8.uscourts.gov/opndir/14/12/141164P.pdf
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