Eastman v. Baker Recovery Services (In Re Eastman)
Shane E. Eastman, a Chapter 7 bankruptcy debtor, initiated an adversary proceeding against Baker Recovery Services and the Law Offices of Juana Trejo. He sought a declaratory judgment, an injunction, and damages, alleging that the defendants violated his discharge injunction, the FDCPA, TDCA, DTPA, and committed intentional infliction of emotional distress by attempting to collect a discharged debt. The court ruled that the defendants indeed violated the Bankruptcy Code's discharge injunction, the FDCPA, and the TDCA, particularly through their actions in filing a lawsuit in California. Consequently, the court granted Eastman's request for an injunction, awarded statutory damages of $1,000, and ordered the defendants to pay attorney's fees and costs. However, Eastman's claims for actual damages were denied due to insufficient proof, and his DTPA and tort claims were dismissed, the former for lack of standing and the latter for failing to meet the required intent threshold.