In Henderson v. Santander Consumer USA (S.Ct. No 16-349,) Justice Gorsuch authored the opinion holding that Santander’s purchase of the CitiFinancial automobile portfolio did not render it a debt collector under the FDCPA. Justice Gorsuch’s folksy writing offered commentary and dicta that undoubtedly will create more litigation. For example, in setting the stage for the issue to be decided, Justice Gorsuch stated, “Disruptive dinnertime calls, downright deceit, and more besides drew Congress’s eye to the debt collection industry. From that scrutiny emerged the Fair Debt Collection Practices Act, a statute that authorizes private lawsuits and weighty fines designed to deter wayward collection practices. So perhaps it comes as little surprise that we now face a question about who exactly qualifies as a “debt collector” subject to the Act’s rigors. Everyone agrees that the term embraces the repo man—someone hired by a creditor to collect an outstanding debt. But what if you purchase a debt and then try to collect it for yourself—does that make you a “debt collector” too? That’s the nub of the dispute now before us.” Of course, not everyone does agree that the repo man is subject to the FDCPA, and many cases hold that the repo man is not subject to the FDCPA. Anyway, the result was correct. . .