Cornelius v. Deere Credit Services, Inc.

CourtDistrict Court, S.D. Georgia
DecidedFebruary 13, 2025
Docket4:24-cv-00025
StatusUnknown

This text of Cornelius v. Deere Credit Services, Inc. (Cornelius v. Deere Credit Services, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cornelius v. Deere Credit Services, Inc., (S.D. Ga. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF GEORGIA SAVANNAH DIVISION

MELVIN CORNELIUS, on behalf of himself Case No.: 4:24-cv-25-RSB-CLR and others similarly situated,

Plaintiff, v.

DEERE CREDIT SERVICES, INC.,

Defendant.

FINAL APPROVAL ORDER AND JUDGMENT

On February 12, 2025, this Court heard the Consent Motion for Final Approval of Class Action Settlement, (doc. 33), and the unopposed Motion for Attorney’s Fees and Expenses filed by Class Counsel, (doc. 30; see also doc. 31).1 This Court reviewed: (a) the motions and the supporting papers, including the Settlement Agreement and Release (“Settlement Agreement”); and (b) counsel’s arguments. Based on this review and the findings below, the Court found good cause to GRANT both motions, (docs 30, 33). FINDINGS: Upon review of the record, the Court hereby finds that the Settlement Agreement is, in all respects, fair, adequate, and reasonable and therefore approves it. The Eleventh Circuit Court of Appeals has identified six factors to be considered in analyzing the fairness of a class action settlement under Rule 23(e): “(1) the likelihood of success at trial; (2) the range of possible recovery; (3) the point on or below the range of possible recovery at which a settlement is fair, adequate and reasonable; (4) the complexity, expense and duration of litigation; (5) the substance

1 Capitalized terms in this Order, unless otherwise defined, have the same definitions as those terms in the Settlement Agreement. See ECF Nos. 25-1, 28-1. and amount of opposition to the settlement; and (6) the stage of the proceedings at which the settlement was achieved.” Bennett v. Behring Corp., 737 F.2d 982, 986 (11th Cir. 1984); see also Leverso v. SouthTrust Bank of AL., N.A., 18 F.3d 1527, 1530 (11th Cir. 1994). Rule 23(e) likewise requires a court to consider several additional factors, including that

the class representative and class counsel have adequately represented the class, and that the settlement treats class members equitably relative to one another. Fed. R. Civ. P. 23(e). Each relevant factor supports the conclusion that the settlement is fundamentally fair, adequate, and reasonable, and should be approved. Among other matters considered, the Court took into account: (a) the complexity of Plaintiff’s theory of liability under the Telephone Consumer Protection Act (“TCPA”); (b) the arguments raised by Deere Credit Services, Inc. (“DCSI”) in its pleadings that could potentially preclude or reduce the recovery by Settlement Class Members; (c) delays in any award to the Settlement Class that would occur due to further litigation and appellate proceedings; (d) the relief provided to the Settlement Class, and how it compares to other TCPA class action settlements that

have been approved; and (e) the recommendation of the Settlement Agreement by counsel for the parties. The Court also considered the lack of objectors to the Settlement Agreement and the lack of exclusion requests, demonstrating that the Settlement Class has a universally positive reaction to the settlement. See Lee v. Ocwen Loan Servicing, LLC, No. 14-60649, 2015 WL 5449813, at *5 (S.D. Fla. Sept. 14, 2015) (“Obviously, a low number of objections suggests that the settlement is reasonable, while a high number of objections would provide a basis for finding that the settlement was unreasonable.”). The Court also finds that extensive arm’s-length negotiations have taken place, in good faith, between Settlement Class Counsel and DCSI’s counsel resulting in the Settlement Agreement. These negotiations were presided over by an experienced mediator, underscoring the fairness of the settlement reached. See James v. JPMorgan Chase Bank, N.A., No. 8:15-cv-2424-

T-23JSS, 2016 WL 6908118, at *2 (M.D. Fla. Nov. 22, 2016) (“No indication appears that the settlement resulted from collusion. Rather, the parties settled with the assistance of [a] court- appointed mediator[.]”) The Settlement Agreement provides substantial value to the Settlement Class in the form of considerable cash payments to each participating Settlement Class Member. The recoveries here compare very favorably to other approved TCPA class action settlements and underscore the fairness and adequacy of the settlement. See, e.g., Lalli v. First Team Real Estate—Orange Cty., No. 8:20-cv-27-JWH, ADS, 2022 WL 8207530, at *12 (C.D. Cal. Sept. 6, 2022) (finding $110 per-class-member recovery to be “a strong result”); James, 2016 WL 6908118, at *2 (“Discounting the statutory award by the probability that Chase successfully defends some class members’

claims, a recovery of $50 per person fairly resolves this action.”) (citing In re Capital One Tel. Consumer Prot. Act Litig., 80 F. Supp. 3d 781, 789 (N.D. Ill. 2015) (finding that $34.60 per person falls “within the range of recoveries” in a TCPA class action)). In addition, because each participating Settlement Class Member will receive the same recovery, the settlement treats class members equitably relative to one another. See Vu v. I Care Credit, LLC, No. 17-cv-04609 RAO, 2022 WL 22871480, at *11 (C.D. Cal. Nov. 4, 2022) (“Here, each member had to submit the same claim form to receive a distribution from the settlement fund and each member who submitted a claim form will receive an equal distribution. As the class members’ TCPA claims are based on the same fax advertisements, equal distributions are fair.”). Notice was provided to Class Members in compliance with the Settlement Agreement, due process, and Rule 23 of the Federal Rules of Civil Procedure. (See doc. 32.) The notice: (i) fully and accurately informed Settlement Class Members about the lawsuit and settlement; (ii) provided sufficient information so that Settlement Class Members could decide whether to accept the

benefits offered, opt-out and pursue their own remedies, or object to the settlement; (iii) provided procedures for Settlement Class Members to file written objections to the proposed settlement, to appear at the hearing, and to state objections to the proposed settlement; and (iv) provided the time, date, and place of the final fairness hearing. Notice was sent to persons identified as a result of reverse look ups performed on potentially affected cellular telephone numbers. This method of identifying class members is reliable and constitutes industry standard best practices in wrong number class actions under the TCPA. See, e.g., Bonoan v. Adobe, Inc., No. 3:19-cv-01068-RS, 2020 WL 6018934, at *2 (N.D. Cal. Oct. 9, 2020). Notice was provided pursuant to 28 U.S.C. § 1715(b), and the notice complies with the

requirements of 28 U.S.C. § 1715(b). Plaintiff and Settlement Class Counsel have fairly and adequately protected the Settlement Class’s interests, and the parties have adequately performed their obligations under the Settlement Agreement. The Court further finds that Class Counsel—Michael L. Greenwald of Greenwald Davidson Radbil PLLC, Anthony I. Paronich of Paronich Law, P.C., and Steven H. Koval of The Koval Firm, LLC—have zealously represented the interests of the Settlement Class.

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Related

Leverso v. Southtrust Bank
18 F.3d 1527 (Eleventh Circuit, 1994)
Amadeck v. Capital One Financial Corp.
80 F. Supp. 3d 781 (N.D. Illinois, 2015)
Bennett v. Behring Corp.
737 F.2d 982 (Eleventh Circuit, 1984)

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Bluebook (online)
Cornelius v. Deere Credit Services, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/cornelius-v-deere-credit-services-inc-gasd-2025.