The Utah Supreme Court reversed the grant of summary judgment to a law firm defendant sued for allegedly improper debt collection 

Tamara Gonzalez, an owner of a condominium unit within Pemberley at Robinson’s Grove Condominium Unit Owners Association (Association), allegedly fell behind on paying her
Association assessment fees. The Association hired a law firm to collect on the delinquent fees. The firm sent demand letters to  Ms. Gonzalez, who upon receipt of the letters, claimed that the letters misrepresented the amount she actually owed. When negotiations between the Association and Ms. Gonzalez fell through, the Association again contacted the law firm for collection services, and the firm subsequently filed a lawsuit against Ms. Gonzalez on behalf of the Association. After several years of proceedings, Ms. Gonzalez brought a counterclaim against the law firm, asserting, in addition to other claims, that the law firm had violated § 1692e of the Fair Debt Collection Practices Act (FDCPA) by misrepresenting the character, amount, and legal status of the debt she owed in the law firm’s demand letters and in its complaint.

Even under a strict liability standard, however, a plaintiff is
still required to make a threshold showing that a misrepresentation
occurred under the FDCPA. And, because the law firm was the
moving party on summary judgment in this case, it bore the initial
burden of showing that it did not engage in an act prohibited by the
FDCPA—or, in other words, that there is no genuine issue of
material fact as to its claims that it made no false representation of
the character, amount, or legal status of Ms. Gonzalez’s debt. Yet the
district court failed to determine whether the law firm had met its
initial burden. We therefore remand the case to the district court to
make such determination.