On July 2, 2014, the US Court of Appeals for the Seventh Circuit, sitting en banc in Suesz v. Med-1 Solutions, LLC, held that the "judicial district or similar legal entity" in which a consumer debt collector must file its debt collection suit under § 1692i of the Fair Debt Collection Practices Act (FDCPA) is the smallest geographic area that is relevant for determining venue in the court system in which the case is filed (No. 13-1821, (7th Cir. July 2, 2014)).

Med-1 Solutions sued Mark Suesz to collect a $1,280 debt that Suez owed to Community North Hospital. Suesz resides in Hancock County, Indiana. Community North Hospital is located in Lawrence Township in the northeast corner of Marion County, a county immediately west of Hancock County. Med-1 Solutions sued Suesz in Pike Township in Marion County. The court issued a judgment against Suesz for $1,280, the validity of which was not questioned on appeal.

Suesz filed an action in federal court, alleging that Med-1 Solutions's practice of filing collection lawsuits in townships where debtors neither live nor signed the contracts on which they are being sued violates the FDCPA's requirement that a debt collector file its collection suit in a "judicial district or similar legal entity" where the contract was signed or where the debtor resides (15 U.S.C. § 1692i). The district court dismissed the case on the basis of the Seventh Circuit's decision in Newsom v. Friedman, which held that intra-county districts used to delineate the venue of small claims cases in Illinois's Cook County Circuit Court were not separate judicial districts for the purposes of § 1692i (76 F.3d 813 (7th Cir. 1996)). The district court reasoned that under Newsom, townships in Marion County are not separate judicial districts and that all of Marion County is the relevant district, giving Med-1 Solutions a wide choice of venue to bring its suit.

The Seventh Circuit reversed the district court and overruled Newsom. The court held that the correct interpretation of "judicial district or similar entity" for the purposes of the FDCPA is the smallest geographic area relevant to venue in the court system in which the case is filed. Because the smallest geographic area in this case is a township in Marion County, not Marion county itself, the court held that Med-1 Solutions cannot bring its case against Suesz in Pike Township, where Suesz neither lives nor signed a contract giving rise to the debt. In its decision, the Seventh Circuit explained that: