In Jackson v. Blitt & Gaines, P.C., 2016 WL 4376514, at *1 (7th Cir. 2016), the Court of Appeals for the Seventh Circuit held that garnishment proceedings are not subject to the FDCPA’s venue provisions.
At issue in this appeal is whether a wage-garnishment action under Illinois law is a “legal action” on a debt against a consumer under the venue provision of the Fair Debt Collection Practices Act (“FDCPA”). We hold that such actions are not against the consumer and therefore affirm the dismissals made by the respective district courts in this consolidated appeal.