Supreme Court of Missouri / Apr 17, 2018
Keith Jackson, Appellant, vs. Dennis J. Barton III, Respondent.
Keith Jackson sued attorney Dennis J. Barton III and LifeSmile Dental Care, alleging violations of the Fair Debt Collection Practices Act (FDCPA) and the Missouri Merchandising Practices Act (MMPA) stemming from debt collection efforts for dental services. The circuit court dismissed Jackson's petition, finding the FDCPA claim time-barred and the MMPA claim failing to state a cause of action. The Supreme Court of Missouri reversed, holding that Jackson's FDCPA claim was not time-barred by discrete acts within the limitations period, and that Barton's collection activities were "in connection with" the sale of dental services for purposes of the MMPA.