Cooper v. Retrieval-Masters Creditors Bureau, Inc., No. 18-2358 (7th Cir. 2022)
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The Seventh Circuit vacated the fee award entered by the district court in this dispute over attorney fee awards to prevailing plaintiffs under consumer-protection statutes where damages are modest and the plaintiff has rejected a substantial early settlement offer, holding that the fee award was an abuse of discretion.
Plaintiff sued Defendant for violating the Fair Debt Collection Practices Act, 15 U.S. 1692 et seq., in attempting to collect a debt. The district court granted summary judgment to Plaintiff on liability and awarded Plaintiff $500. Plaintiff and his attorneys then sought an award of attorney fees and costs of more than $66,000. The district court awarded fees and costs of less than $8,000. The Seventh Circuit vacated the award, holding that the district court's refusal to grant any post-offer fees was an abuse of discretion.
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