2023 Supreme(US)(ca8) 417
COURT OF APPEALS FOR THE EIGHTH CIRCUIT
Adrianna Beckler – Appellant
Versus
Rent Recovery Solutions LLC – Respondent
No. 23-1142 ___________________________
Adrianna Beckler
lllllllllllllllllllllPlaintiff - Appellant
v.
Rent Recovery Solutions, LLC
lllllllllllllllllllllDefendant - Appellee ____________
Appeal from United States District Court for the District of Minnesota ____________
Submitted: June 15, 2023 Filed: October 5, 2023 ____________ Before LOKEN, ERICKSON, and KOBES, Circuit Judges. ____________ LOKEN, Circuit Judge.
In May 2021, debt collector Rent Recovery Solutions (“RRS”) called Adrianna Beckler to collect an alleged $900 debt to her former landlord. Beckler said she disputed the debt and asked RRS to send written documentation to support the claim. In June, without sending the documents to Beckler, RRS reported her debt to TransUnion, a credit reporting agency, failing to tell TransUnion that the debt was disputed. Beckler commenced this action against RRS, alleging that it violated the Fair Debt Collection Practices Act (“FDCPA”) by failing to provide requested documents, reporting the debt to TransUnion without providing the documents, and failing to tell Trans Union the debt was disputed. See 15 U.S.C. §§ 1692g(a) and (b), 1692e(8). Beckler sought actual damages, $1,000 in statutory damages, and reasonable attorneys’ fees. See §§ 1692k(a)(1), (a)(2)(A), (a)(3). RRS answered the Complaint and promptly made an offer of judgment for $2,000 plus reasonable attorneys’ fees, which Beckler accepted. See Fed. R. Civ. P. 68(a).
Beckler requested an award of $18,810 in attorneys’ fees for work by two
attorneys and a paralegal. RRS challenged the fees requested by both attorneys, who
submitted sworn declarations and detailed billing records. The district court,1
applying the lodestar method of calculating an attorney fee award, found that the
attorneys’ claimed hourly rates were reasonable but the hours expended on the case
were excessive. The court reduced the claimed attorney hours by fifty percent,
exclusive of paralegal work, and awarded Beckler $9,480 in attorneys’ fees. Beckler
appeals. Reviewing the district court’s award for abuse of discretion, we affirm. See
Miller v. Dugan,
Beckler’s attorneys accuse the district court of departing from the lodestar calculation by imposing a “cap” that violates FDCPA policies and deprives counsel of full compensation for bringing consumer enforcement actions under this complex federal statute. We disagree.
“The starting point for determining attorneys’ fees is the ‘lodestar,’ which is
calculated by multiplying the number of hours reasonably expended by the reasonable
hourly rate.” Orduno v. Pietrzak,
1 The Honorable Wilhelmina M. Wright, United States District Judge for the District of Minnesota.
-2-
otherwise unnecessary.” Hensley v. Eckerhart,
The court began by thoroughly reviewing the question of attorney hourly rates, finding “that the claimed hourly rates are reasonable and consistent with the rates in this community for similar services by lawyers of comparable experience.” It then conducted a detailed review of hours performed on specific tasks by the two attorneys, concluding that many hours spent on pre-complaint research and communicating with each other and the client were excessive or redunda