In the case of Rotkiske v. Klemm, 2019, the U.S. Supreme Court ruled that a one-year statute of limitations for lawsuits under the Fair Debt Collection Practices Act (FDCPA) begins to run when an alleged violation occurs, not when it is discovered by the plaintiff. The petitioner Kevin Rotkiske accumulated credit card debt between 2003 and 2005 which his bank referred to respondent Klemm & Associates for collection. In 2008, after unsuccessful attempts at collecting from Rotkiske's former address, they served someone who allegedly accepted service on behalf of him leading to a default judgment against him in March 2009. He only became aware about this judgement in September 2014 and sued Klemm alleging violations of FDCPA but was dismissed due to expiration of one-year limitation period since he knew or should have known about these violations before filing suit in June 2015.

In the dissenting opinion for ROTKISKE v. KLEMM, Justice Ginsburg disagreed with the majority's interpretation of the Fair Debt Collection Practices Act (FDCPA). She argued that it was not Congress' intent to limit consumers' ability to sue debt collectors who use deceptive practices. Instead, she believed that Congress intended a "discovery rule" approach where the one-year statute of limitations begins when an individual discovers or should have discovered their injury. In this case, Rotkiske did not discover his injury until more than a year after Klemm & Associates filed suit against him due to alleged fraudulent service notice by Klemm & Associates. Therefore, according to Justice Ginsburg’s view on FDCPA and its discovery rule provision, Rotkiske should still be able to bring his claim forward despite being outside of what is traditionally considered as limitation period.