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Mark Suesz v. Med-1 Solutions, LLC
Citations: 757 F.3d 636; 2014 U.S. App. LEXIS 12562; 2014 WL 2964771Docket: 13-1821
Court: Court of Appeals for the Seventh Circuit; July 2, 2014; Federal Appellate Court
Original Court Document: View Document
The United States Court of Appeals for the Seventh Circuit addressed the interpretation of the Fair Debt Collection Practices Act (FDCPA), specifically the requirement that debt collection suits be filed in the appropriate jurisdiction as defined by 15 U.S.C. § 1692i. The case involved Mark Suesz, who contested a suit filed against him by Med-1 Solutions, LLC in Pike Township Small Claims Court. Suesz argued that the suit violated § 1692i because the contract was not signed in Pike Township, nor did he reside there. The court noted a precedent from Newsom v. Friedman, which determined that intra-county divisions in Illinois were not separate judicial districts for venue purposes. However, the appellate court, upon rehearing en banc, concluded that the correct interpretation of "judicial district or similar legal entity" in § 1692i should be the smallest relevant geographic area for determining venue, which for Marion County’s small claims courts is a township. This led to the reversal of the district court's judgment and the overruling of Newsom, allowing for stricter venue adherence and reducing the potential for abusive forum-shopping by debt collectors. The factual background indicated Suesz, a resident of Hancock County, had a debt with Community North Hospital, which transferred the debt to Med-1 Solutions. Med-1 subsequently filed suit in Pike Township, resulting in a judgment against Suesz, which was not challenged in this federal case. The appellate court reviewed the dismissal of Suesz's claim de novo, treating his allegations as true and drawing favorable inferences for the plaintiff. Suesz filed a lawsuit against Med-1 under the Fair Debt Collection Practices Act (FDCPA), claiming that Med-1 routinely initiates collection lawsuits in small claims courts in Marion County townships where debtors do not reside or sign contracts. Suesz sought to certify a class of plaintiffs, but the district court dismissed the case without addressing this motion. Relying on the precedent set in Newsom, the court determined that the townships in Marion County do not qualify as 'judicial districts' under § 1692i, leading to the dismissal of Suesz’s suit. The FDCPA aims to eliminate abusive debt collection practices, as seen in cases like Muha and Jacobson. The Act addresses the tendency of debt collectors to pursue lawsuits for consumer debts that are often too small to warrant litigation, typically resulting in default judgments that enable wage garnishment without significant legal expense for the collector. Debt collectors frequently choose inconvenient or favorable courts to increase the likelihood of default by debtors, who may lack legal knowledge or resources. The Act restricts debt collectors to suing in the judicial district where the consumer signed the contract or resides unless the debt is secured by real estate, in which case the lawsuit must be filed where the property is located. Violations of these provisions can result in the debt collector being liable for damages and attorney fees. However, the term 'judicial district' is not clearly defined in the FDCPA, creating ambiguity, especially in states like Indiana and Illinois where courts are organized by county. The statutory term in question was intentionally drafted broadly to encompass varying court systems across the country, including the township small claims courts in Marion County. The analysis focuses on the implications of venue rules regarding the interpretation of 'judicial district or similar legal entity.' The panel majority's preference to rely on state definitions of 'judicial district' is problematic, as the term lacks a defined meaning in state law. Furthermore, if Congress intended to adopt state jurisdiction and venue rules, it would not have imposed federal venue limitations on debt collectors; the presence of such provisions indicates Congress's intent to restrict where debt collection lawsuits can be initiated, contrasting with state law. The township small claims courts in Marion County, distinct from the general jurisdiction of county-wide courts, are designated as separate judicial entities under Indiana law. Each of the nine townships operates its own small claims court, with separate judges and jurisdiction over civil cases with claims not exceeding $6,000. These courts are funded and managed by township governments, reinforcing their status as independent judicial districts. The panel's decision allowing debt collectors to choose among these courts risks undermining the Fair Debt Collection Practices Act's venue provisions, effectively nullifying Congress's intent to regulate where debt collectors can file suits. Indiana's venue statute aligns with this interpretation, establishing that venue in small claims cases in Marion County is determined by township jurisdiction. Indiana Code § 33-34-3-1 outlines the jurisdiction and venue rules for small claims courts, specifying that cases (excluding landlord-tenant claims) may be venued, commenced, and decided in any township small claims court within the county. A defendant can file a motion for change of venue within ten days of being served, prompting the court to determine the appropriate venue. The determination process follows a specific order, prioritizing the location of the transaction or occurrence related to the claim, consented venue in writing by the defendant, or the residence of the defendants. If no other township qualifies, the case can remain in the township where it was filed. For landlord-tenant claims, venue must be where the real estate is located. The excerpt also highlights changes made to the small claims courts following a Voting Rights Act lawsuit, which addressed the election of judges by township versus their authority over the entire county, significantly impacting African-American voting power. The settlement led to legislation that maintained township elections while enhancing the independence of township courts and establishing venue by township. The Indiana Public Law 95-1999 sought to address disparities in voting populations for judicial elections by linking election districts for judges with their court venues, which was deemed a legitimate aspect of evaluating compliance with 42 U.S.C. § 1973. Despite the 1999 changes, defendants sued in the incorrect township court were required to appear within ten days to request a change of venue, risking remaining in a potentially inconvenient court if they missed the deadline. The township small claims courts remained interconnected and under the jurisdiction of the Marion Circuit Court, which was responsible for providing assistance, establishing uniform rules, and facilitating case transfers between courts. An investigative task force highlighted significant venue issues, noting that many defendants were unaware of their right to transfer cases based on their residency. Furthermore, the decentralized structure of the township courts, limited public transport, and the practices of debt collectors complicated access for defendants, making it less convenient than a centralized system. The task force raised concerns about large-volume filers exploiting township courts for favorable outcomes and the pressure on judges to prioritize revenue generation from filing fees. Judicial statistics indicated that judges who scrutinized settlement terms experienced a decrease in new filings, suggesting a trend towards less oversight in some courts. The term “judicial district” lacks a definitive statutory meaning, providing flexibility in interpretation, with varied judicial approaches observed in cases involving unique court structures like those in Marion County and Cook County, Illinois. The adopted approach emphasizes state court venue rules and defines the relevant judicial district as the smallest geographic area pertinent to venue in the court where a case is filed. This interpretation aims to prevent abusive forum-shopping by debt collectors, aligning better with the debtor-protective policy of the Fair Debt Collection Practices Act (FDCPA) compared to alternative methods. It is also presented as more predictable and straightforward than Newsom’s multi-factor test, which complicates the analysis with numerous court administration details. In the case of Newsom, a 'municipal department district' in the Cook County Circuit Court was deemed not to qualify as a 'judicial district or similar legal entity' under § 1692i of the FDCPA. A court order specified that civil actions should be filed in the district where the defendant resides or where the transaction occurred. Newsom argued that the term 'judicial district' in the FDCPA has a clear meaning that excludes a 'municipal department district.' This interpretation relied on a legal dictionary definition from the time of the FDCPA's enactment, which described 'judicial districts' as areas commonly divided for judicial purposes, typically with a court of general jurisdiction. However, this dictionary definition is criticized for its vagueness, suggesting it does not resolve the issue effectively. The definition includes ambiguous terms like 'commonly divided' and 'may include,' which, combined with the FDCPA's allowance for 'similar legal entity,' suggest that Cook County’s divisional courts and Marion County’s small-claims courts could be classified as 'judicial districts.' Furthermore, the dictionary's legal basis is questioned, lacking a clear connection to the FDCPA's enactment, raising concerns about the appropriateness of relying on it for statutory interpretation. The fourth edition of the legal document retained four specific cases, while the fifth edition (1979) maintained the definition of 'judicial district' unchanged since the second edition but omitted citations without explanation. The editor may have realized that the previous case citations did not substantiate the definition. Although the definition might imply that a judicial district is legislatively created and includes one or more counties, the cited cases (Lindsley, Hoar, and Consolidated Flour Mills) complicate this interpretation. Lindsley and Hoar addressed the division of counties into smaller districts, while Consolidated Flour Mills rejected a challenge to jurisdiction following a county's reassignment between districts, offering a broad semantic definition of 'judicial district' focused on political arrangements for electing judges rather than geographical boundaries. The Gardner case reiterated that even within the same judicial district, courts of different counties remain distinct and cannot exercise jurisdiction over cases from one another, effectively treating the counties as separate districts. The loose definition of 'judicial district' in Black’s Law Dictionary lacked a solid legal foundation, as evidenced by the deletion of case citations in the 1979 edition and the complete removal of the definition in the 1999 edition. Moreover, there is no evidence that the drafters of the Fair Debt Collection Practices Act considered this definition relevant, as their primary concern was 'forum abuse'—the practice of filing lawsuits in inconvenient jurisdictions to obtain default judgments against consumers. In response, the Act established fair venue standards requiring debt collectors to file suits where consumers reside or where the contract was signed, a measure endorsed by the Federal Trade Commission to prevent such abuses without overly restricting debt collectors. The Senate Committee report advocating for the Act, which prioritized preventing abusive forum-shopping over vague dictionary definitions, holds more authority in interpreting statutory terms. The judicial administration approach in Newsom also emphasized the importance of court administration in venue requirements for small claims cases within specific subdistricts of Cook County. The court opinion determined that the entire county constitutes the relevant judicial district for venue under the Fair Debt Collection Practices Act (FDCPA). This conclusion stemmed from a previous court order allowing cases to be assigned to any judge or courtroom in the county without dismissals based on improper filing locations. The analysis highlighted that the administrative structure of the Cook County Circuit Court, which operates under a single chief judge, does not impose territorial limits on judicial authority. However, the majority panel faced reluctance to deviate from this reasoning due to stare decisis, ultimately likening the venue limitations of township small claims courts in Marion County to the Cook County precedent. Despite this, the application of the Newsom decision was critiqued for undermining the protective intent of § 1692i, which aims to prevent abusive forum-shopping by debt collectors. By categorizing the entire county as a judicial district, debt collectors gained the ability to pursue cases in courts that could be inconvenient for debtors, thus creating an imbalance. The implications of this reasoning are particularly severe for larger counties, like San Bernardino County, which spans over 20,000 square miles and features multiple court divisions. The expansive geography could lead to significant inconveniences for debtors if the same logic were applied, allowing debt collectors to choose courts based solely on strategic advantages rather than proximity or relevance. Additionally, the township small claims courts in Marion County possess more autonomy compared to the Cook County courts, having distinct administrative structures established to address constitutional concerns under the Voting Rights Act. Dissenting opinions do not find the distinctions between Cook County and Marion County compelling, asserting that differences in judicial administration are irrelevant to the intent of § 1692i or the Fair Debt Collection Practices Act (FDCPA). The approach taken aligns with the Second Circuit's ruling in Hess v. Cohen, where a debt collection suit was improperly filed in a city court lacking jurisdiction because the debtor did not reside there. The Second Circuit reversed the district court's dismissal, emphasizing that the relevant 'judicial district' for FDCPA compliance is defined by state laws governing territorial jurisdiction, which are distinct from jurisdictional issues. The ruling clarified that these geographic limits, while waivable, should inform venue determinations under the FDCPA. This reasoning is applicable not only to the New York city courts but also to similar structures in Marion County and San Bernardino County, reinforcing the adaptability of the FDCPA's venue provisions to various state court systems. Additionally, a precedent from Arizona confirmed that separate judicial districts exist under the FDCPA despite a unified state court system, further supporting the interpretation that venue must align with the debtor's location. The "venue approach" aims to simplify understanding of court systems, avoiding confusion between small claims courts that are part of larger courts versus independent ones. Distinctions based on administrative details, such as case transfers for convenience or judge substitutions, complicate matters for debt collectors and debtors and do not address the issue of preventing abusive forum-shopping for consumer debt collection. The Fair Debt Collection Practices Act (FDCPA) does not dictate how states should structure their court systems or their procedures, meaning a debt collector can comply with state law and secure valid state court judgments while simultaneously violating the FDCPA by incorrectly choosing a venue. For instance, if state law permits venue where the plaintiff does business but a collector files in that location regardless of where the defendants reside, it is state-compliant yet FDCPA-violating. These violations do not invalidate state judgments but open avenues for federal remedies against the collector. The FDCPA accepts the state court structure as determined by each state, with Section 1692i establishing federal venue requirements for consumer debt cases. These federal regulations can be violated even if state laws are adhered to regarding venue. Legislative history clarifies that FDCPA venue provisions apply only to consumer debt collectors without altering broader state venue laws. Additionally, the source of state venue rules—be it statute, court rule, or other mechanisms—does not affect their relevance under Section 1692i. Consequently, a consumer debt collector in Marion County retains a limited venue selection, with small claims courts having concurrent jurisdiction with county circuit and superior courts, which have county-wide venue authority. A debt collector may file suit in either a circuit or superior court in the center of the county, or in a township small claims court where venue is determined at the township level, adhering to the FDCPA's restrictions against abusive forum-shopping. Circuit and superior courts can transfer small claims cases to the appropriate township court, which occurs routinely. The county clerk's office informs litigants that cases seeking judgments of $6,000 or less must be filed in small claims court, which is not supported by the county clerk's office. Filing fees are lower in small claims courts ($82) compared to circuit and superior courts ($141), and small claims courts generally process cases faster, making them more appealing to debt collectors. The court's interpretation of 15 U.S.C. § 1692i requires reversing the district court's judgment and remanding for class certification and merits consideration. Med-1 Solutions requests that any overruling of precedent (Newsom) be applied prospectively, citing reliance on that precedent by debt collectors. However, applying new rules only prospectively raises constitutional concerns, as courts traditionally announce new rules in the context of the cases before them and apply them to those parties. The Supreme Court permits prospective application in civil cases to avoid injustice but does not find sufficient grounds to limit the current decision to prospective application, stating that reliance on prior law alone does not justify such a limitation. Reynoldsville Casket Co. v. Hyde established that a new U.S. Supreme Court ruling cannot be applied only prospectively if a state court's decision is reversed. Reliance on prior intermediate appellate court decisions does not provide sufficient certainty to warrant prospective application to protect settled expectations, as highlighted in Anderson-Bey v. Zavaras and Hawknet, Ltd. v. Overseas Shipping Agencies. However, in Nunez-Reyes v. Holder, the Ninth Circuit allowed prospective effect to align circuit law with other circuits. Prospective overruling is only permissible if the law was well settled enough for the community to rely on it. In this case, the dismissal of the action is reversed, and it is remanded for further proceedings. The case revolves around the interpretation of the “venue provision” in the Fair Debt Collection Practices Act (FDCPA), specifically 15 U.S.C. § 1692i, which mandates that debt collectors must file suit in the judicial district where the consumer resides or where the contract was signed. The term “judicial district” lacks a clear definition, complicating its application in various state court systems. The panel relied on the definition from Black’s Law Dictionary and state court rules to interpret it, and the en banc court considered whether to overrule Newsom v. Friedman to adopt a new interpretation of “judicial district or similar legal entity.” The concurrence supports the decision to overrule Newsom. Concerns regarding federalism are echoed, aligning with Judge Flaum's dissent, while ultimately reaching the same conclusion as the majority opinion regarding Section 1692i, a federal statute that sets venue rules for consumer debt collection actions, including those in state courts. Typically, consumer debt lawsuits are state-law claims for breach of contract and are predominantly filed in state courts due to the lack of a sufficient amount-in-controversy for federal diversity jurisdiction, with average collection amounts being around $1,500. There is skepticism about Congress's authority to impose procedural rules on state-law claims in state courts. Although Congress can create causes of action that require state courts to follow federal procedural rules related to those claims, the application of federal procedural rules in state court primarily pertains to federal claims. The question remains unresolved whether Congress can dictate procedural rules for state-law claims in state courts, a matter the Supreme Court has acknowledged but not decided in previous cases, including Jinks v. Richland County, which discussed the tolling of statutes of limitations on supplemental state-law claims. The Court affirmed the necessity of the tolling provision as essential for Congress to execute its powers related to establishing inferior tribunals under the Constitution. The provision was deemed a substantive rule, not a procedural one, allowing the Court to avoid addressing concerns about state sovereignty raised by the challenger regarding Congress's authority over state court procedures. In Pierce County v. Guillen, the Court upheld 23 U.S.C. § 409, which protects state-collected traffic data from being used in court, as a valid exercise of Congress's power under the Commerce Clause. Although challenges based on Tenth Amendment principles were noted, the Court did not address them due to the lower court's lack of examination. The current case focuses solely on statutory interpretation while considering federalism principles. The Court acknowledged that § 1692i does not dictate state court operations but creates a federal venue rule for debt-collection actions. However, it emphasized that state sovereignty allows states to manage court systems and procedural rules, necessitating an interpretive approach to avoid constitutional issues when applying this statute to state courts. Section 1692i is characterized not as a venue rule but as a penalty for debt collectors misusing state venue laws in ways deemed unfair or abusive by Congress, as per 15 U.S.C. 1692k(a). This section allows for civil remedies against debt collectors who fail to comply with the provisions of the subchapter. However, there are constitutional concerns regarding Congress's authority to regulate venue rules in state courts. If Congress cannot set venue rules for state courts, it may also lack the power to impose federal penalties on litigants for noncompliance with federally prescribed venue rules. The presence of the venue provision in the Act indicates congressional dissatisfaction with state law's authority over the filing of consumer debt collection suits, raising questions about Congress's limits in regulating state court venue. While it is argued that 1692i does not alter state jurisdiction and venue rules but merely imposes limits on where debt collectors may sue, there is skepticism about the appropriateness of this in the context of state sovereignty over judicial rules. Section 1692i indirectly overrides state venue rules by imposing a federal damages remedy for noncompliance with federal requirements. Although Congress may sometimes exercise indirect regulation, the validity of this approach in this context is uncertain. While 1692i may be a valid exercise of Congress’s power under the Commerce Clause, its constitutionality under the Tenth Amendment remains unresolved, as laws permissible under the Commerce Clause can still violate federalism principles. Tenth Amendment challenges can be raised by private parties, necessitating careful interpretation of 1692i in light of Congress’s limitations and the structure of each state's court system and rules. To avoid liability under the Fair Debt Collection Practices Act (FDCPA) for violations of Section 1692i, a debt collector must file suit in the “judicial district” where the consumer resides or contracted the debt. The term “judicial district” is ambiguous due to varying state court structures, which may not uniformly use the term “district” or may define it differently in relation to compliance with Section 1692i. Judges Hamilton and Posner argue that the definition from Black’s Law Dictionary, which associates the term with the court’s territorial authority and general jurisdiction, does not clarify this ambiguity. They emphasize the importance of state venue rules and the structure of state court systems in determining the relevant “judicial district.” The primary goal of Section 1692i is to promote a venue convenient for the consumer debtor, which supports interpreting the phrase as the judicial subdivision relevant to venue as defined by state law. This interpretation resolves statutory ambiguity but leaves constitutional questions unresolved. Additionally, the FDCPA does not impose liability on debt collectors for using higher courts instead of local courts if state law permits such actions, indicating the need to respect state procedural rules. For instance, under Indiana law, small-claims jurisdiction in township courts is concurrent with circuit and superior courts, although the township courts are not courts of record. Debt collectors tend to favor township courts, yet the interpretation of § 1692i of the Fair Debt Collection Practices Act (FDCPA) should not penalize them for utilizing courts of record if permitted by state law. Compliance with § 1692i should hinge on the judicial subdivisions relevant for venue in the chosen court system, supporting the majority's decision to overturn prior rulings and remand for further proceedings. Conversely, dissenting opinions argue that the majority's definition of "judicial district" as the smallest geographic venue is not mandated by the statutory text. The dissent emphasizes that when Congress did not define "judicial district," it intended to refer to the definitions established by state governments. In Indiana, for example, township courts are part of the broader Marion County judicial district. The dissent critiques the majority for imposing a more stringent rule than Congress intended, arguing that the overarching purpose of protecting debtors should not lead to a misinterpretation of statutory language. Thus, while § 1692i restricts the venues for filing debt collection actions, it should adhere to state-defined judicial districts without federalizing the term. Section 1692i of the Fair Debt Collection Practices Act (FDCPA) does not alter the definition of judicial districts. The prevailing interpretation suggests that it makes 1692i ineffective by implying that Congress intended to adopt state jurisdictional rules without a federal prohibition. However, this interpretation overlooks two critical points. First, 1692i enforces stricter penalties on debt collectors who violate state jurisdiction and venue rules, aimed at preventing them from filing suits in inconvenient locations that hinder consumer participation. Without these federal provisions, such practices would have minimal consequences. Second, 1692i imposes significant limitations, mandating that filings occur only in the judicial district where the debtor resides or signed the contract, even if state rules allow filings in the debtor's workplace district. The dissenting view emphasizes that judicial districts arise from legislative action, not solely from venue rules, and states can establish districts based on various considerations beyond venue. The evidence of congressional intent indicates that Congress sought to maintain state authority over venue rules without imposing a new federal definition of judicial districts. The dissent argues that Congress would not have deemed it unfair for debt collectors to file suits within state-defined judicial districts, even if not in the most convenient venue. The reference to existing state judicial districts in the FDCPA reflects Congress's intention to respect state law, as seen in the Federal Trade Commission's standards that accommodate state structures. Overall, the dissent contends that the majority’s interpretation risks altering the balance of state and federal jurisdiction without clear congressional intent. Judge Kanne's dissent highlights that the majority's rule in federal debt-collection actions diverges from Congressional intent. The precedent set in *Newsom v. Friedman*, 76 F.3d 813 (7th Cir. 1996), affirms that states define their own judicial districts, referencing the definition from Black's Law Dictionary at the time the FDCPA was enacted, which describes judicial districts as subdivisions for judicial purposes with courts of general original jurisdiction. *Newsom* balances debtor protection with the complexities of state court systems, directing attention to state law, specifically court rules, for defining judicial districts. In Indiana, Judge Kanne argues that the proper judicial district is the county rather than the township. For example, debt collectors filing in superior courts, which are county-level courts of general jurisdiction, must file in the appropriate county, satisfying both the new rule and *Newsom*, as counties represent the smallest venue for superior court actions. The situation is more complicated with limited-jurisdiction courts, such as township courts, where it is unclear if they are subdivisions of larger districts or independent judicial districts. The *Newsom* analysis investigates how these courts operate and the territorial restrictions on filing, seeking to determine the proper judicial district as defined by state law, aligning with what Congress likely intended. The majority opinion critiques the historical basis of the Black's Law definition but fails to provide useful insights. In contrast, *Newsom* utilizes this practical definition to guide courts while allowing flexibility for states to define their judicial districts. Ultimately, *Newsom* aligns closely with the Second Circuit's decision in *Hess v. Cohen*, emphasizing the need to consider state law specifics in defining judicial districts, particularly regarding the authority of local courts based on residency restrictions. A defendant from outside a designated zone who objected in court had their case dismissed due to improper filing under state law, leading the Hess court to determine that the city court constituted a separate judicial district under New York law. In contrast, the courts in Newsom were not classified as judicial districts because the filing of debt collection suits was not deemed improper. The dissent argues that the majority's new rule fails to respect state court structure. The case revolves around the interpretation of "judicial district or similar legal entity" within the Fair Debt Collection Practices Act (FDCPA). The dissent references the earlier ruling in Newsom v. Friedman, which provided a clear, plain-meaning interpretation of the term. It emphasizes the principle of stare decisis, asserting that circuit precedent should not be overturned without compelling reasons, such as changes in law or practical application. The dissent warns against overruling past decisions merely due to disagreement, highlighting that adherence to precedent is fundamental to judicial authority and stability. The principle of stare decisis in statutory interpretation is emphasized, underscoring its importance in maintaining legal consistency. Despite the majority's authority to overturn previous decisions when sitting en banc, there is no valid justification provided for overruling the prior decision in Newsom. The majority claims that the definition of terms from Newsom and Black's Law Dictionary is vague and inadequately supported, but these criticisms are deemed insufficient to discard established law. The majority subsequently redefines "judicial district or similar legal entity," but this new definition is criticized for being incorrect and lacking adherence to established statutory construction principles. The dissent argues that the original phrase is unambiguous, asserting that the majority's reliance on legislative intent and policy considerations is misguided. The original panel's reliance on Black's Law Dictionary aligns with standard interpretive practices, which dictate that terms should be understood based on their ordinary meanings when statutory definitions are absent. Blind reliance on dictionary definitions can be problematic, yet the dictionary in question offers a definition that aligns with common sense, as noted by Judge Flaum. The majority’s quest for an authoritative source behind Black’s definition is questioned, given that dictionaries are descriptive and reflect common usage, which evolves over time. The definition of "judicial district" from Black's is deemed clear, directing to the concept of "circuits or precincts" for judicial purposes, particularly in Indiana, where the state is divided into judicial circuits per the Indiana Constitution and statutes. Most counties have their own judicial circuits, while the Indiana legislature has established superior courts in many areas to manage judicial workload. Though county structures may vary, they all fall within a judicial circuit, which serves as the standard division for judicial purposes. The Marion County Small Claims Courts are highlighted as an exception, being unique in structure and not representative of a common division within the state court system. The majority's dismissal of the Newsom/Black’s definition as vague is criticized, as the definition is said to be clear, and the pursuit of a new definition without a statutory or authoritative basis contradicts proper statutory construction. The argument emphasizes familiar understanding of "judicial district," asserting that the intent of Congress in using the term is clear and comprehensible. The term "judicial district" should be interpreted according to its established meaning within the federal court system, as frequently referenced in the United States Code. While most debt collection actions occur in state courts, the Fair Debt Collection Practices Act (FDCPA) also applies to federal court actions, a fact recognized by Congress. The rising incidence of federal court debt collection actions, particularly concerning student loans, highlights the relevance of the FDCPA in these contexts. Federal government debt collection suits can be filed in federal court without regard to the amount in controversy, and while these suits are exempt from FDCPA when initiated by the government, private contractors collecting on defaulted loans may not be similarly exempt, creating ambiguity in application. It is crucial to acknowledge that the legal principle being discussed is applicable across all court systems within the jurisdiction, including federal courts. The majority opinion's failure to consider the straightforward application of "judicial district" creates unnecessary ambiguity. The determination of statutory language clarity should be based solely on the language and context of the statute, not influenced by unique case specifics. The law remains constant despite challenging circumstances, and any perceived ambiguity does not justify the majority's interpretation of the statute, which does not align with the established definitions. The matter raises the question of how to appropriately compare state court systems within this framework. The model under discussion identifies a federal judicial district as a key legal entity, aligning with the definition of a "judicial district or similar legal entity." It identifies Indiana’s constitutionally authorized judicial circuits as fitting this definition, in contrast to Marion County Small Claims Courts, which do not meet the criteria. The author critiques the majority's approach, arguing that it improperly replaces established legal terminology with new phrasing that skews statutory interpretation in favor of an equitable outcome rather than a legally sound one. The author emphasizes that ambiguity in statutes should lead to clarification through legislative history, not replacement of terms. Concerns are raised regarding the majority’s disregard for stare decisis and statutory construction principles, which the author believes results in inconsistent and illogical outcomes that conflict with the statutory text and intent. Specifically, the majority’s definition implies that some federal judicial districts are not "judicial districts" while their subdivisions are, which contradicts the established understanding of geographical units for venue determination. The author asserts that divisions within judicial districts are indeed relevant geographic areas, tied to county lines, challenging the majority's rationale for including entire districts based solely on administrative details. The majority's approach to defining "judicial district" is criticized for leading to inconsistent results within the judicial system, particularly highlighted through the example of Indiana's small claims courts. Specifically, the definition creates disparities between counties, as Marion County’s small claims court is treated differently from those in Shelby, Saint Joseph, Allen, or Jasper Counties. This inconsistency raises concerns about the arbitrary nature of the majority's ruling, which appears to favor Marion County residents without providing similar protections for impoverished individuals in rural areas of Indiana. The dissenting opinion questions the rationale behind a definition of "judicial district" that varies significantly within the same court system, suggesting it undermines Congress's intent to create uniform federal limitations on debt collectors' venue choices. The majority's reliance on state venue rules, which can change at any time, ultimately frustrates the purpose of establishing consistent protections under the Fair Debt Collection Practices Act (FDCPA). Additionally, while acknowledging the issue of forum shopping by debt collectors in Marion County, the dissent notes that Indiana is already addressing this problem. The majority is criticized for disregarding the principle of stare decisis and for failing to engage adequately in statutory interpretation, leading to a result that lacks general applicability across various court systems. The dissent supports Judge Flaum's adherence to the previous decision in Newsom and argues for a more consistent approach to defining "judicial districts" as the judicial circuits themselves, rather than specific courts within those circuits.