Can you sue for mistakes in collection letters?

The plaintiff debtor in  Jerman sued a law firm and an attorney for FDCPA violations, committed while they were acting as debt collectors. The FDCPA has a notice provision that requires debt collectors to send written notice to the debtor that the debt will be assumed valid unless the debtor disputes it.  15 U.S.C. § 1692g(a).  The collection attorney’s notice letter in  Jerman stated that the mortgage debt at issue would be assumed valid unless the debtor disputed that debt  in writing. 
The  Jerman plaintiff debtor contended that the collection attorney violated the FDCPA by imposing a requirement that the debtor dispute the debt  in writing, when the FDCPA required only that the debtor dispute the debt and did not specify that it be in writing.  Observing that authority was split on the issue, the district court ultimately agreed with the plaintiff debtor that this writing requirement in the collection attorney’s notice letter constituted an FDCPA violation. ).  In a later proceeding, however, the district court held that the collection attorney was entitled to the bona fide error defense. 

The Supreme Court ruled that the FDCPA’s bona fide error defense does not encompass mistakes of law or misinterpretations of the requirements of the Act itself.  Instead, the seven-member majority concluded that  § 1692k(c)’s requirement that debt collectors maintain procedures reasonably adapted to avoid any bona fide errors referred only to measures designed to avoid errors like clerical or factual mistakes.

Jerman v. Carlisle, McNellie, Rini, Kramer & Ulrich LPA, 559 U.S. , 130 S. Ct. 1605, 176 L. Ed. 2d 519 (2010).