In the case of Munoz v. Pipestone Financial, LLC, Civil No. 04-4142 (JNE/SRN) (D.Minn. 8/30/2007), the Plaintiff claimed that Pipestone Financial, LLC, and Messerli & Kramer, P.A., (collectively, Defendants) violated the Fair Debt Collection Practices Act (FDCPA) by attempting to collect interest at an impermissible rate, misrepresenting their entitlement to attorney fees, and using envelopes that reveal personal and confidential information about him in communications with him. The court held in part as follows:

[S]tipulated attorneys’ fees are no part of the original debt; [and] the right to them does not accrue until the payee incurs the liability, and then only to the extent of the reasonable value of the attorneys’ services actually performed or to be performed, which must be proved. . . . The full amount for which the maker is liable on such stipulations is not really due when suit is brought, for the services of the attorney are not then fully performed.

Therefore, if a collection letter include legal fees then that collection letter violates the FDCPA.