Andrew Ladick brought suit against Gerald J. Van Gemert, an attorney, alleging that Van Gemert…

Andrew Ladick brought suit against Gerald J. Van Gemert, an attorney, alleging that Van Gemert had sent him a letter on behalf of a California condominium association demanding payment of a pastdue condominium assessment fee. He alleged that the letter violated the Fair Debt Collection Practices Act (FDCPA) because it failed to give a “validation notice” and did not expressly disclose that Van Gemert was attempting to collect a debt and that any information obtained would be used for that purpose. The trial court found that the condominium assessment that Van Gemert sought to collect was not a “debt” under the FDCPA and granted summary judgment to Van Gemert. Ladick appealed. On appeal, Van Gemert argued that a condominium assessment does not involve an extension of credit and is more like a tax than a debt. Should the FDCPA apply to this transaction?

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