Alexander Ross v. Robinson, Hoover & Fudge, PLLC

── Alexander Ross v. Robinson, Hoover & Fudge, PLLC ── Court: Court of Appeals for the Sixth Circuit Date: April 22, 2026 Category: General RECOMMENDED FOR PUBLICATION Pursuant to Sixth Circuit I.O.P. 32.1(b) File Name: 26a0120p.06 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT ┐ ALEXANDER ROSS, │ Plaintiff-Appellant, │ > No. 25-1802 │ v. │ │ ROBINSON, HOOVER & FUDGE, PLLC, │ Defendant-Appellee. │ ┘ Appeal from the United States District Court for the Eastern District of Michigan at Detroit. No. 2:24-cv-11717—Denise Page Hood, District Judge. Decided and Filed: April 22, 2026 Before: SILER, MOORE, and BLOOMEKATZ, Circuit Judges. _________________ COUNSEL ON BRIEF: John A. Evanchek, Curtis C. Warner, KELLEY & EVANCHEK, Canton, Michigan, for Appellant. Eugene Xerxes Martin, IV, MARTIN GOLDEN LYONS WATTS MORGAN PLLC, Dallas, Texas, for Appellee. _________________ OPINION _________________ KAREN NELSON MOORE, Circuit Judge. Alexander Ross and his then-wife bought a used car in Oklahoma. After he and his wife divorced, Ross moved to Michigan. Following his move, the former couple failed to make their car payments and their creditor hired Robinson, Hoover & Fudge, PLLC (“RHF”), an Oklahoma-based law firm, to bring a breach-of-contract action against Ross and his ex-wife in Oklahoma. Ross eventually defaulted. By that time, RHF had learned that Ross was living and working in Michigan. RHF then used the Oklahoma  No. 25-1802 Ross v. Robinson, Hoover & Fudge, PLLC Page 2 default judgment to submit a garnishment summons to the Oklahoma registered agent of Ross’s employer’s parent company. The parent company passed the garnishment summons to Ross’s employer, which began garnishing wages Ross earned in Michigan. Ross then filed this action in the U.S. District Court for the Eastern District of Michigan, bringing claims under the Fair Debt Collection Practices Act (“FDCPA”), 15 U.S.C. § 1692 et seq., and the Michigan Regulation of Collection Practices Act (“MRCPA”), Mich. Comp. Laws § 445.251 et seq. The district court dismissed the complaint after finding that RHF had not purposefully established minimum contacts with Michigan. Because RHF purposefully directed its actions at Ross, intentionally targeting him in Michigan and causing him to suffer his injury in the forum state, we REVERSE the judgment of the district court and REMAND for further proceedings consistent with this opinion. I. BACKGROUND In February 2018, Ross and his then-wife lived outside of Tulsa, Oklahoma and jointly purchased a used 2014 Toyota Scion Xb from a Tulsa-based auto dealership. R. 1 (Compl. ¶¶ 9– 13)1; R. 7-3 (Purchase Agreement at 1–6) (Page ID #91–96). Following the sale, the dealership assigned its rights under the purchase agreement to Auto Advantage Finance LLC (“AAF”). R. 1 (Compl. ¶ 10). Within a year of their purchase, Ross and his wife divorced, and Ross moved to Michigan in July 2019. R. 1 (Compl. ¶¶ 11–12); R. 10-2 (Ross Aff. ¶ 3) (Page ID #198). He obtained a Michigan driver’s license and notified the U.S. Postal Service of his new