HUBER v. SIMON'S AGENCY, INC., 2:19-cv-01424

Plaintiff Jamie Huber, represented by attorneys Zelman and Marcus, prevailed individually on a Fair Debt Collection Practices Act (FDCPA) § 1692e claim after summary judgment and appeal.
Defendant Simon’s Agency, Inc. conceded that Huber qualifies as a prevailing party entitled to attorneys’ fees and costs but challenged the amount sought.
Huber sought $3,326.25 in costs and $147,219.04 in attorneys’ fees, submitting billing records and declarations supporting her attorneys’ rates and hours worked.
Defendant accepted all requested costs and the reasonableness of hourly rates but sought exclusions for certain billed hours and argued for a substantial downward fee adjustment due to Huber’s partial success.
The court undertook a meticulous lodestar analysis, evaluating hours claimed, rate reasonableness, and proposed reductions for non-compensable work and overall limited success.
Ultimately, the court awarded full costs and sharply reduced attorneys’ fees—to $59,513.90—applying a 60% downward adjustment from lodestar due to the limited success on class claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to attorneys’ fees and costs	Huber is a prevailing FDCPA plaintiff and should recover fees	Huber is entitled to fees, but amount is contested	Huber met statutory threshold and is entitled to fees/costs
Reasonableness of hours expended	All claimed hours are reasonable and necessary	30.9 hours are vague, duplicative, admin, or otherwise improper	Only clearly non-compensable/admin hours excluded
Reasonableness of hourly rates	Proposed rates are justified by skill, inflation, and market	Hourly rates not disputed, conform to local Philadelphia rates	Updated CLS rates, with inflation adjustment, are appropriate
Downward adjustment for degree of success	No reduction; Huber achieved complete success	75% reduction needed for limited/individual (not class) success	60% reduction due to related but unsuccessful class claims

Hensley v. Eckerhart, 461 U.S. 424 (Supreme Court sets lodestar methodology and discretionary adjustments for degree of success)
Graziano v. Harrison, 950 F.2d 107 (Third Circuit mandates fee awards to prevailing FDCPA plaintiffs)
Rode v. Dellarciprete, 892 F.2d 1177 (Allocates burdens for proving reasonableness and opposing excessive fee requests)
Pennsylvania Envtl. Def. Found. v. Canon-McMillan Sch. Dist., 152 F.3d 228 (Provides standards for attorneys’ hourly rate evaluation in fee awards)
Maldonado v. Houstoun, 256 F.3d 181 (Community Legal Services (CLS) schedule as basis for prevailing market rates in Philadelphia)
Texas State Teachers Ass'n v. Garland Indep. Sch. Dist., 489 U.S. 782 (Defines prevailing party status for fee-shifting statutes)