Robinson v. Sherman Financial Group, LLC, 2:12-cv-00030

Plaintiff Ralph Robinson sued multiple debt-collection defendants under the FDCPA, alleging false, deceptive, or misleading communications; jury found only Hosto liable and awarded $1,000 in statutory damages.
Plaintiff sought $110,623.75 in fees through trial and $14,970 post-trial plus $387.80 costs; Magistrate Judge recommended $45,000 in fees and $387.80 costs.
Both parties objected; district court conducted de novo review of Plaintiff’s objections to the recommended fee amount.
Court applied the lodestar method (reasonable hours × reasonable hourly rate), excluding hours that were excessive, redundant, or unrelated to successful claims.
Court set hourly rates at $250 for lead counsel Alan Lee and $200 for co-counsel Everett Mechem, excluded specific hours tied to unrelated licensing claims and other excessive entries, applied a 15% reduction to the lodestar for residual unrelated work, and awarded $53,350.25 in fees plus $387.80 costs.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Entitlement to attorney’s fees under FDCPA	Robinson is entitled to reasonable fees after prevailing on §1692e claim against Hosto	Hosto did not dispute entitlement but contested amount	Court: Robinson entitled to fees; amount calculated by lodestar with exclusions/adjustment
Reasonable hourly rates	Counsel requested $325 (Lee) and $275 (Mechem) as contingency-market rates	Hosto argued rates were excessive compared to local market	Court: adopted local-market rates of $250 (Lee) and $200 (Mechem) based on prior district awards and experience
Compensable hours for time spent against other defendants	Robinson argued hours on overlapping claims and common facts against multiple defendants are compensable	Hosto argued only time directly related to Hosto is compensable; many hours were for LVNV-related claims	Court: excluded hours spent on distinct LVNV-only issues (default motion, licensing claim), allowed time for overlapping work, and removed other excessive/duplicative entries
Adjustment to lodestar for degree of success & residual unrelated work	Robinson sought full lodestar; argued shared factual core justified fees for most work	Hosto urged substantial reduction because most effort targeted LVNV defendants and unsuccessful claims	Court: after excluding specific hours, applied a 15% downward adjustment to account for remaining licensing-related work not specifically segregable; awarded $53,350.25; costs $387.80 granted

Hensley v. Eckerhart, 461 U.S. 424 (1983) (lodestar method; exclude hours not "reasonably expended")
Fox v. Vice, 563 U.S. 826 (2011) (fee-shifting aims to do "rough justice")
Wayne v. Vill. of Sebring, 36 F.3d 517 (6th Cir. 1994) (successful plaintiff may recover fees for work on related claims against dismissed defendants when common core of facts exists)
Mary Beth G. v. City of Chicago, 723 F.2d 1263 (7th Cir. 1983) (hours on a claim relating to several defendants may be counted if nonliability was not frivolous)
Cobb v. Miller, 818 F.2d 1227 (5th Cir. 1987) (endorsing Mary Beth G. where claims against different defendants arise from same course of conduct)
Adcock-Ladd v. Sec'y of Treasury, 227 F.3d 343 (6th Cir. 2000) (reasonableness standard for fee awards; lodestar foundation)
Pennsylvania v. Del. Valley Citizens’ Council for Clean Air, 478 U.S. 546 (1986) (lodestar strongly presumed reasonable)