The Fourth Circuit reversed the denial of attorneys fees by the District Court,  finding that while only nominal actual damages were awarded,  attorneys fees were still allowed.

The Court of Appeals held that while Farrar v. Hobby, 506 U.S. 103 (1992) and Mercer v. Duke Univ., 401 F.3d 199 (4th Cir. 2005)  held that when a Plaintiff  "received only nominal damages, 'the only reasonable fee is . . . no fee at all.'” Quotiing Farrar, 506 U.S.

As the  FDCPA is concerned “with the substance of the transaction as opposed to the form”,  the 4th Circuit held that even assuming that the original 2004 debt was  a commercial loan, the later 2006 debt,  used to satisfy the original obligation,  was a consumer loan as it concerned the Plaintiff's personal finances, his personal residence, and was taken out in his own name. This case may also have value in determining whether a debtor "debts are primarily consumer debts"  under  11 U.S.C.

The Fourth Circuit Court of Appeals held that "the Code plainly provides" that a debtor does not have to actually claim an exemption in order to use Code section 522(f) to avoid a judicial lien that impairs the exemption.