Does Of Mean After?

[Baker, John]

The question in my subject line is inspired by the recent opinion of the United States Court of Appeals for the Sixth Circuit in Wallace v. Diversified Consultants, http://www.ca6.uscourts.gov/opinions.pdf/14a0054p-06.pdf.  Under the Fair Debt Collection Practices Act, a collector dunning someone for payment must notify the individual that it will assume the validity of the debt unless he disputes it "within thirty days after receipt of the notice."  A debt collector gave the notice but used the words "within 30 days of receiving this notice."

The court ruled that "within 30 days after" and "within 30 days of" mean the same thing.  It acknowledged that "within 30 days of" could also mean "within 30 days before," but that meaning was implausible.  It actually strikes me as a very sound analysis - if there are any errors in it, I would be interested in hearing them.  As a nice bonus, the court didn't resort to the dictionary once.


John Baker

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