Mabe v. G.C. Services Ltd. Partnership
Docket: Nos. 94-1154 to 94-1157
Court: Court of Appeals for the Fourth Circuit; August 5, 1994; Federal Appellate Court
Child support payments do not qualify as "debts" under the Fair Debt Collection Practices Act (FDCPA), according to the ruling from the United States Court of Appeals. The case arose from a contract between the Commonwealth of Virginia and G.C. Services Limited Partnership (GCS), wherein GCS was tasked with collecting delinquent child support payments assigned to the state by families receiving Aid to Families with Dependent Children (AFDC) benefits. Appellants argued that GCS's collection letters violated the FDCPA, but the district court dismissed their complaints for lack of jurisdiction, finding that child support obligations do not meet the FDCPA's definition of "debt." The FDCPA defines "debt" as any obligation of a consumer to pay money arising from transactions primarily for personal, family, or household purposes. The court noted that the obligations in question stemmed from an administrative support order and were not incurred to acquire consumer goods or services; rather, they were imposed to ensure parental support for children. Furthermore, the court clarified that a private contract's inclusion of federal standards does not create federal-question jurisdiction. Therefore, since the child support obligations do not fit the FDCPA's definition of "debt," the appeals were dismissed, and the district court's decision was affirmed.