Manpreet Singh v. Experian Information Solutions, Inc.; Trans Union, LLC; and Discover Bank

Summary

The United States District Court for the District of Minnesota partially granted Manpreet Singh’s motion for attorneys’ fees and costs following his acceptance of a Rule 68 offer of judgment from Midland Credit Management, Inc. In an action alleging Fair Credit Reporting Act violations, the court awarded $20,175 in attorneys’ fees and $211.25 in costs, in addition to the $7,500 offer-of-judgment payment, for a total of $27,886.25. The court addressed the reasonableness of counsel’s hourly rate, hours expended, administrative tasks, work involving co-defendants, fee-petition preparation, and litigation costs.

Holdings

1. A $425 hourly rate for plaintiff’s consumer-law attorney was reasonable under the circumstances.
2. The hours reasonably expended were compensable, subject to deductions for wholly administrative tasks and time spent correcting an oversight.
3. Routine clerical tasks are not compensable at attorney or paralegal billing rates, but minor administrative tasks performed alongside substantive work may be compensable.
4. No across-the-board 75 percent reduction was warranted because Midland did not identify specific improperly billed entries or show that the requested work was attributable to other defendants.
5. The court awarded reasonable fees for preparing the fee petition but declined to award fees for preparing the reply because that request was raised for the first time in the reply brief without a supplemental motion.
6. Midland was responsible for $211.25 in costs, consisting of the service-of-process fee and Midland’s 25 percent share of shared initial filing and pro hac vice fees.

Questions Presented

1. What amount of attorneys’ fees was reasonable under Midland’s Rule 68 offer of judgment and the lodestar method?
2. Whether counsel’s requested hourly rate of $425 was reasonable for the work performed in the Twin Cities market.
3. Whether deductions were required for administrative tasks, unnecessary work, work attributable to other defendants, co-counsel communications, or fee-negotiation conduct.
4. What costs were properly attributable to Midland under the offer of judgment?
5. Whether fees for time spent preparing the reply brief could be awarded when first requested in the reply rather than by supplemental motion.

Disposition

other