Portalatin v. Blatt, Hasenmiller, Leibsker & Moore LLC, 1:14-cv-08271

Portalatin sued Blatt and Midland under the FDCPA, alleging improper venue: Blatt sued in Cook County First Municipal District instead of the plaintiff’s Fourth Municipal District. Portalatin settled with Midland; case proceeded against Blatt.
Court granted Portalatin summary judgment on liability, rejecting Blatt’s "bona fide error" defense; the Seventh Circuit later rejected that defense en banc in Oliva.
Trial proceeded only on statutory damages; Portalatin sought $1,000, the jury awarded $200. Judgment entered for Portalatin; Blatt appealed but appeal stayed pending Oliva.
Portalatin sought attorney’s fees and $772.95 in costs under 15 U.S.C. § 1692k(a)(3). Blatt contested the reasonableness of the requested fees.
Three attorneys worked on the case: Badwan (primary, requested $375/hr for 161.5 hours), Wooten (trial counsel, requested $550/hr for 64.5 hours sought), and Zambon (time not sought). Blatt produced its own billing showing comparable rates and hours.
Court evaluated reasonable hourly rates and hours, reduced Wooten’s rate and hours, made modest reductions to Badwan’s hours, and awarded $69,393.75 in attorney’s fees plus $772.95 costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Portalatin is a prevailing party entitled to fees	Portalatin prevailed on liability and obtained statutory damages	Blatt did not dispute prevailing-party status	Portalatin is a prevailing party under §1692k(a)(3)
Reasonable hourly rates for attorneys	Badwan $375/hr; Wooten $550/hr	Blatt challenges Wooten’s $550 and contends rates are excessive	Approved Badwan at $375; set Wooten at $425 due to lack of supporting evidence for $550
Reasonable number of hours expended	Sought stated hours for Badwan and Wooten as reasonably necessary	Blatt argues duplication and excessive hours given overlap with other similar cases	Approved 148.5 hours for Badwan (reduced modestly); reduced Wooten’s hours by half to 32.25 as excessive; further modest reductions for clerical/status and fee-petition time
Whether fee award should be reduced for limited success	Portalatin argues full fee justified by liability win, statutory cap on damages, and public-interest vindication	Blatt argues small damages ($200) mean limited success and fee reduction warranted	Court declined to reduce fee for limited success: liability ruling and public interest support full award

Hensley v. Eckerhart, 461 U.S. 424 (1983) (lodestar method and reasonableness factors for fee awards)
Gastineau v. Wright, 592 F.3d 747 (7th Cir. 2010) (apply Hensley to FDCPA fees)
Oliva v. Blatt, Hasenmiller, Leibsker & Moore, LLC, 864 F.3d 492 (7th Cir. 2017) (bona fide error defense rejected en banc)
Pickett v. Sheridan Health Care Ctr., 664 F.3d 632 (7th Cir. 2011) (criticizing use of Laffey Matrix for Chicago rates)
Barrow v. Falck, 977 F.2d 1100 (7th Cir. 1992) (defendant cannot litigate tenaciously then complain about plaintiff’s fees)
City of Riverside v. Rivera, 477 U.S. 561 (1986) (public-interest considerations in fee awards)
Zagorski v. Midwest Billing Servs., Inc., 128 F.3d 1164 (7th Cir. 1997) (public policy and fee considerations in consumer litigation)
Spegon v. Catholic Bishop of Chicago, 175 F.3d 544 (7th Cir. 1999) (billing judgment and avoiding duplicative fee requests)