United States Third Circuit

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St. Pierre v. Retrieval-Masters Creditors Bureau, Inc., 17-1731

Held that unpaid highway tolls are not the type of debt that can support a claim under the federal Fair Debt Collection Practices Act (FDCPA). A driver who failed to pay tolls on the New Jersey Turnpike because his electronic payment account was in arrears filed a class-action complaint alleging that a debt collection agency used impermissible means to collect the debt. Affirming dismissal of his complaint, the Third Circuit held that highway tolls are a legal obligation in the nature of a tax that falls outside the scope of the FDCPA.

Appellate Information

  • Decided
  • Published 2018/08/07


  • Krause


  • United States Third Circuit