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Green v. Portfolio Recovery Associates, LLC, Record No. 0144-22-3, Rehearing en banc granted

Case Briefs

March 19, 2024

By: Juli M. Porto

Virginia Appellate Law Blog

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The Court of Appeals does not release any new published opinions today, but it does grant a rehearing en banc of the split panel opinion Green v. Portfolio Recovery Associates, LLC, Record No. 0144-22-3. The panel opinion represented a rare appellate win for a pro se litigant.


Portfolio Recovery Associates (PRA) was a debt buyer that filed a debt collection action against Green. PRA claimed it owned Green’s debt through a series of assignments. The panel opinion disagreed that PRA had traced the chain of its title to Green’s specific debt. It therefore held that PRA had no standing to sue Green. The panel dissent, on the other hand, believed that whether PRA owned the debt that it claimed Green owed was not a standing question, but an evidentiary sufficiency issue comprising part of PRA’s case-in-chief. Since Green’s assignment of error only addressed PRA’s standing, and not the sufficiency of its evidence, the dissent did not address the merits of that issue.

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