Frazier v. Castle Ford, Ltd., 27 A.3d 583

Frazier purchased a Ford Premium Care Extended Service Plan from Crystal Ford on December 23, 2004; Robbins altered the contract to reflect a December 31, 2008 expiration and assured coverage until that date.
In November 2006, Frazier learned his warranty had expired in October 2006; Crystal Ford admitted miscalculating the duration and extended the warranty, reimbursing repairs, after Frazier incurred $552.99 out of pocket.
Frazier filed a class action on July 27, 2007 alleging fraud and deceptive trade practices under the Consumer Protection Act, seeking damages, fees, and injunctive relief for himself and a putative class.
Crystal Ford extended the warranty to December 31, 2008 and reimbursed repairs; Crystal Ford then moved to deny class certification and for summary judgment; Frazier sought discovery.
The circuit court denied class certification, granted summary judgment on all issues except attorney’s fees, and later awarded Frazier $20,950.52 in attorney’s fees after a separate hearing.
Crystal Ford cross-appealed, challenging the attorney’s-fees award as encompassing fees for class-related efforts; the court affirmed, concluding the award encompassed the full litigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the court err in granting summary judgment for Crystal Ford?	Frazier asserts material facts remain; punitive damages/injunctive relief may still be viable.	No injury proven; relief already provided; punitive/injunctive damages unavailable without injury.	No error; summary judgment proper; punitive damages unavailable without compensatory damages; injunctive relief moot.
Did the court err in denying class certification?	Certification should not be denied on mootness alone; common issues exist.	Relief to named plaintiff moots the entire action; certification inappropriate.	No error; entire action moot; denial of class certification correct.
Did the court abuse discretion in denying discovery?	Additional class-related discovery and punitive-damages evidence were necessary.	Discovery would not affect mootness or lack of compensatory damages; punitive damages require compensatory backing.	No abuse of discretion; discovery not necessary given mootness and damages posture.
Did the court abuse discretion in awarding attorney's fees for the entire litigation?	Fees should reflect efforts to obtain relief for Frazier only.	Fees can reflect broader benefits to Frazier and class-related relief, even if class certification failed.	No abuse; fees awarded for entire litigation; court reasonably considered broader results benefiting similarly situated consumers.

Blaylock v. Johns Hopkins Federal Credit Union, 152 Md.App. 338 (2003) (factors for determining reasonable attorney's fees)
Caldor, Inc. v. Bowden, 330 Md. 632 (1993) (requirements for punitive damages (need compensatory damages))
Philip Morris, Inc. v. Angeletti, 358 Md. 689 (2000) (underlying compensatory damages prerequisite for punitive damages)
Shabazz v. Bob Evans Farms, Inc., 163 Md.App. 602 (2005) (punitive damages require compensatory damages; private CMA claim must show actual injury)
Lloyd v. GMC, 397 Md. 108 (2007) (actual injury required under Consumer Protection Act)
Creveling v. Government Employees Insurance Co., 376 Md. 72 (2003) (whether mootness defeats class certification post-tender depending on timing)
Barber v. American Airlines, Inc., No. 241 Ill. 2d 450, 350 Ill. Dec. 535, 948 N.E.2d 1042 (2011) (mootness where tender before motion for class certification; distinction from Roper)
Roper v. Consurve, Inc., 578 F.2d 1106 (5th Cir. 1978) (tender before certification can keep appeal viable; distinguish bar from this case)
Eastside Vend Distribs., Inc. v. Pepsi Bottling Grp., Inc., 396 Md. 219 (2006) (injunctive relief and class-action considerations in context of consumer protection)
Anne Arundel Cnty., Md. v. Halle Dev., Inc., 408 Md. 539 (2009) (standard of review for class certification matters)