Associates Fin. Servs. Co. v. Hornik
In Associates Fin. Servs. Co. v. Hornik, 114 Wis. 2d 163, 167, 336 N.W.2d 395 (Ct. App. 1983) the Court addressed the prohibited practice under Wis. Stat. 427.104(1)(g)-communicating with the debtor in ways that "can reasonably be expected to threaten or harass the customer." Id. at 168.
The Court stated:
"Creditors have a duty to act reasonably when collecting debts from their debtors, and in sec. 427.104 the legislature codifies rules describing the duty of care debt collectors owe to debtors." Id. at 167.