Class Actions, Multipliers, Private Attorney General, Reasonableness Of Fees: $1.174 Million Award To Class Counsel In Fair Debt Collection Practices Case Affirmed On Appeal

Significant Benefit Incurred, If Injunctive Relief Was Considered, And Other Objections Were Not Specific To Justify Any Reduction.

               In Doskocz v. ALLS Lien Services, Case No. A166299 (1^st Dist., Div. 1 May 20, 2024) (partially published; fee discussion unpublished), class counsel prevailed on behalf of plaintiffs in case involving some novel and complex issues under the Fair Debt Collection Practices Act and unrelated case.  Class counsel moved for $1.174 million in attorney’s fees, inclusive of a 1.25 multiplier, being granted the full request.  The defense appealed, but to no avail.  A significant benefit was incurred, when both limited monetary and injunctive relief were considered in tandem.  Many other requested defense reductions were not supported with sufficient detail.  A multiplier was justified based on the factors found relevant by the lower court with respect to novel and complex issues.  The defense could not surmount the abuse of discretion standard applied to the fee issues at play.