The Shifting Sands of Res Judicata in the Fourth Circuit – Part 2

By Mark C. Leffler and Emily Connor Kennedy
click here for part 1
Recently, debt collectors have had reasons to celebrate. Two decisions, Midland Funding, LLC v. Johnson and Covert v. LVNV Funding, LLC, have provided them with protection against liability under the Fair Debt Collection Practices Act (FDCPA) for their actions in filing proofs of claim in bankruptcy cases in order to collect defaulted consumer debts. In Covert v. LVNV Funding, LLC, 779 . . .

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