4th Circuit: Randle v. H & P Capital- Attorney’s Fees for FDCPA Claim

Summary: Randle brought a complaint against the Defendants for violations of the FDCPA and sought certification of her case as class action. Prior to any class certification, the Defendants settled, agreeing to pay $6,000 “in full final settlement of all her claims,” plus attorney’s fees related to her individual claims. Counsel then submitted requests for $89,083.69, which was reduced by the district court to $76,876.59. The Defendants appealled, arguing that the district court abused its discretion because the attorney’s fees awarded failed to consider the lack of success in obtaining a class claim. The Court of Appeal rejected this argument, recognizing that while a nominal damages award bears on the propriety of fees awarded, See Farrar v. Hobby, 506 U.S. 103, 114 (1992), the settlement in this case was not nominal, as it was six times the maximum statutory damages. For a copy of the opinion, please see: Randle v. H& P Capital- Attorney’s Fees for FDCPA Claim.pdf