Darnell Murphy v. Bureau Investments Group Portfolio, LLC

Murphy v. Bureau Investments Group Portfolio · United States District Court for the Eastern District of Missouri, Eastern Division · January 9, 2026 · No. 4:24CV1433 HEA

Summary

The United States District Court for the Eastern District of Missouri grants the defendant's cross-motion for summary judgment in an FDCPA action arising from the collection and reporting of a consumer loan. The court concludes that the defendant established a valid chain of title, properly validated the debt, ceased collection activity when disputes were received, and presented uncontroverted evidence that it did not violate the FDCPA. The court orders that an appropriate judgment accompany the opinion.

Holdings

  1. Summary judgment was proper because the undisputed evidence showed that Defendant validly acquired and sought to collect Murphy's debt, while Murphy offered no evidence of an act or omission prohibited by the FDCPA.

Questions Presented

  1. Whether Defendant was entitled to summary judgment on Murphy's FDCPA claims because the undisputed evidence established a valid debt, Defendant's right to collect it, and proper debt validation.
  2. Whether Murphy presented evidence creating a genuine dispute of material fact that Defendant engaged in conduct prohibited by the FDCPA.

Disposition

other

Cases Cited (10)

  • Celotex Corp. v. Catrett, 477 U.S. 317, 322-23 (1986)(followed)
  • Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248, 250, 255-56 (1986)(followed)
  • Bedford v. Doe, 880 F.3d 993, 996 (8th Cir. 2018)(followed)
  • Nissan Fire & Marine Ins. Co. v. Fritz Cos., 210 F.3d 1099, 1106 (9th Cir. 2000)(followed)
  • Adickes v. S.H. Kress & Co., 398 U.S. 144, 158-59 (1970)(followed)
  • Zelkowitz v. Avant, LLC, No. 25-CV-850 (SRN/DLM), 2025 WL 3237906, at *2 (D. Minn. Nov. 20, 2025)(followed)
  • Kowouto v. Jellum Law, P.A., 672 F. Supp. 3d 699, 702 (D. Minn. 2023)(followed)
  • Mayfield v. Portfolio Recovery Assocs., LLC, 553 F. Supp. 3d 676, 683 (D. Minn. 2021)(followed)
  • Freyermuth v. Credit Bureau Services, Inc., 248 F.3d 767, 771 (8th Cir. 2001)(followed)
  • Gallamore v. Portfolio Recovery Assocs., LLC, No. 1:24-CV-00148-SNLJ, 2025 WL 1809794, at *2 (E.D. Mo. July 1, 2025)(followed)

Cited In (0)

No citing cases on record yet.

Court Document

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