Background
Alexander Ross, a Michigan resident, purchased a car in Oklahoma with his then-wife. After they divorced and Ross moved to Michigan, the creditor hired Robinson, Hoover & Fudge, PLLC, an Oklahoma law firm, to collect the debt. RHF obtained a default judgment in Oklahoma and subsequently sent garnishment summonses to entities employing Ross in Michigan, including Detroit Diesel. RHF began withholding wages Ross earned in Michigan. Ross sued RHF in the Eastern District of Michigan, alleging violations of the Fair Debt Collection Practices Act and the Michigan Regulation of Collection Practices Act. The district court dismissed the case, finding RHF lacked minimum contacts with Michigan.
The court’s reasoning
The Sixth Circuit reviewed the dismissal de novo, viewing facts in the light most favorable to the plaintiff. The court applied the three-part test for specific personal jurisdiction: purposeful availment, relationship between the claim and contacts, and reasonableness. The court held that RHF purposefully directed its activities at Michigan by garnishing wages earned by a Michigan employee, relying on the Calder v. Jones framework rather than Walden v. Fiore. The court found that RHF knew Ross lived and worked in Michigan and intentionally targeted his Michigan earnings. The court also concluded that Michigan’s long-arm statute authorized jurisdiction because the alleged tortious conduct caused consequences in the state.
RHF has seized the Michigan wages of Ross, a Michigan resident, allegedly violating the FDCPA and the MRCPA in the process. In doing so, RHF has purposefully directed its allegedly unlawful actions at Ross in Michigan, fully aware that, in the end, Ross would be injured there.
Ross v. Robinson, Hoover & Fudge, PLLC, No. 25-1802 (6th Cir. Apr. 22, 2026)
What it means going forward
Debt collection firms must recognize that garnishing wages earned by a resident in a specific state can establish personal jurisdiction in that state, even if the underlying judgment originated elsewhere.
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