District Court (Cal.) Holds Rent is a “Debt” Subject to the FDCPA

In Leasure v. Willmark Communities, Inc., 2011 WL 2267598 (S.D.Cal. 2011), Judge Lorenz found no controlling Ninth Circuit authority holding that rent was not a debt under the FDCPA and, accordingly, found that rent was debt under the FDCPA, following Romea v. Heiberger & Assoc., 163 F.3d. 111, 114-15 (2d Cir. 1998).