Midwest Recovery Services v. Wolfe

SNELL, Justice.

This appeal concerns the scope of the Iowa Debt Collection Practices Act (the Act). See generally Iowa Code §§ 537.-7101-.7103 (1987). Appellant, Midwest Recovery Services (Midwest), challenges the district court's order finding Midwest liable for numerous violations of the Act, claiming the Act does not apply to the collection of checks originally negotiated for cash.

This appeal originated as two separate small claims actions filed in Polk County by Midwest, an Iowa corporation, in early March, 1988. Both actions sought treble damages under Iowa Code section 554.3806 (1987),…