Can a debt collector be held liable for misrepresenting the legal status of a debt?

Section 1692e prohibits debt collectors from using "any false, deceptive, or misleading representation or means in connection with the collection of any debt," including, as relevant here, misrepresenting the "character, amount, or legal status" of a debt; threatening to "take any action that cannot legally be taken"; or threatening a debtor with arrest, imprisonment, or seizure of property if the debtor fails to make a payment. 15 U.S.C. 1692e. A representation is "deceptive" under section 1692e if it is "open to more than one reasonable interpretation, at least one of which is inaccurate." Easterling v. Collecto, Inc., 692 F.3d 229, 233 (2d Cir. 2012).