April Ann Nelson v. Navient Solutions, LLC; Navient Credit Finance Corporation; Allied Interstate, LLC
July 14, 2026·25-2800·Panel Decision·By James Taylor
The United States Court of Appeals for the Eighth Circuit affirmed the dismissal of a pro se complaint alleging violations of the Fair Debt Collection Practices Act. The court concluded that the district court did not err in dismissing the case following a de novo review.
April Ann Nelson filed a pro se complaint in the United States District Court for the Southern District of Iowa, Western Division, raising claims under the Fair Debt Collection Practices Act against Navient Solutions, LLC, Navient Credit Finance Corporation, and Allied Interstate, LLC. The district court dismissed the complaint, prompting Nelson to appeal.
The court’s reasoning
The panel conducted a de novo review of the district court’s dismissal. The court concluded that the district court did not err in dismissing the case. The court cited Plymouth County v. Merscorp, Inc., 774 F.3d 1155, 1158 (8th Cir. 2014) as the standard for review.
What it means going forward
The affirmation of the dismissal means the pro se complaint under the Fair Debt Collection Practices Act remains dismissed, and the motion to supplement the record is denied as moot.
