ALEXANDER ROSS v. ROBINSON, HOOVER & FUDGE, PLLC - Articles

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Posted by: Azya Thornton on Apr 23, 2026

Court: 6th Circuit Court (Published Opinions)

Attorneys 1: ON BRIEF: John A. Evanchek, Curtis C. Warner, KELLEY & EVANCHEK, Canton, Michigan, for Appellant.

Attorneys 2: ON BRIEF: Eugene Xerxes Martin, IV, MARTIN GOLDEN LYONS WATTS MORGAN PLLC, Dallas, Texas, for Appellee.

Judge(s): SILER, MOORE, and BLOOMEKATZ, Circuit Judges

Court Appealed: United States District Court for the Eastern District of Michigan at Detroit

KAREN NELSON MOORE, Circuit Judge. Alexander Ross and his then-wife bought a used car in Oklahoma. After he and his wife divorced, Ross moved to Michigan. Following his move, the former couple failed to make their car payments and their creditor hired Robinson, Hoover & Fudge, PLLC (“RHF”), an Oklahoma-based law firm, to bring a breach-of-contract action against Ross and his ex-wife in Oklahoma. Ross eventually defaulted. By that time, RHF had learned that Ross was living and working in Michigan. RHF then used the Oklahoma default judgment to submit a garnishment summons to the Oklahoma registered agent of Ross’s employer’s parent company. The parent company passed the garnishment summons to Ross’s employer, which began garnishing wages Ross earned in Michigan. Ross then filed this action in the U.S. District Court for the Eastern District of Michigan, bringing claims under the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692 et seq., and the Michigan Regulation of Collection Practices Act (“MRCPA”), Mich. Comp. Laws § 445.251 et seq. The district court dismissed the complaint after finding that RHF had not purposefully established minimum contacts with Michigan. Because RHF purposefully directed its actions at Ross, intentionally targeting him in Michigan and causing him to suffer his injury in the forum state, we REVERSE the judgment of the district court and REMAND for further proceedings consistent with this opinion.

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