Dana Schwartz, on behalf of herself and all others similarly situated v. State Farm Mutual Automobile Insurance Company, State Farm Fire and Casualty Company, and State Farm General Insurance Company

District Court, D. New Mexico·Decided August 25, 2026·No. 1:18-cv-00328·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO _______________________

DANA SCHWARTZ, on behalf of herself and all others similarly situated,

Plaintiff,

v. No. 1:18-cv-00328-KWR-SCY

STATE FARM MUTUAL AUTOMOBILE INSURANCE COMPANY, STATE FARM FIRE AND CASUALTY COMPANY, and STATE FARM GENERAL INSURANCE COMPANY,

Defendants.

MEMORANDUM OPINION AND ORDER GRANTING PLAINTIFF’S MOTION FOR ATTORNEYS’ FEES AND COSTS AND NAMED PLAINTIFF’S INCENTIVE FEE

THIS MATTER comes before the Court on Plaintiff’s Motion for Attorneys’ Fees and Costs and Named Plaintiff’s Incentive Fee (Doc. 170). Now that Plaintiff has complied with the notice requirement of Federal Rule of Civil Procedure 23, the Court considers her Motion seeking attorneys’ fees and costs, as well as an incentive fee award for Named Plaintiff. Having reviewed the briefing, exhibits, and relevant law, the Court finds that the Motion is well-taken and, therefore, is GRANTED. The Court incorporates herein the order and judgment entered concurrently herewith. BACKGROUND This Motion for attorneys’ fees and costs arises from a class settlement between insureds (Plaintiff and class) against insurers (Defendants). Their dispute involved the sufficiency of Defendants’ disclosure of the Schmick offset regarding UM/UIM coverage. In her class action, Plaintiff’s central argument was that Defendants’ UIM coverage at minimum levels had no meaningful value under Schmick v. State Farm Mutual Automobile Insurance Co., 1985-NMSC- 073, 103 N.M. 216, 704 P.2d 1092, and that Defendants failed to properly inform her of the resulting illusory coverage. In early 2026, the parties reached an agreement to settle the class’s claims. See Settlement Agreement, Doc. 161-1. The Settlement Agreement provides settlement class members with a

partial refund of the premiums paid during the class period, up to an aggregate cap of $20,925,000.00. Id. at 14. Minimum and non-minimum UM/UIM coverage holders will be eligible for 21% and 13% of the total UM/UIM coverage premiums paid during the class period, respectively. Id. If valid claims exceed the aggregate cap, settlement class members’ payments will be subject to a pro rata reduction. Id. As relevant here, on July 16, 2026, the Court certified the settlement class, approved Plaintiff’s motion for final class settlement, and overruled the objection filed by Alain Hielo. Order Finally Approving Settlement, Doc. 180. Because Plaintiff had not yet met the notice requirement of Federal Rule of Civil Procedure (“Rule”) 23(h), the Court delayed ruling on the

Motion until class counsel directed notice to the class in accordance with Rule 23(h)(1). Id. at 29. Based on the circumstances, the Court required Plaintiff to reopen the objection period and predominantly post the Motion on the settlement website, along with objection information, for at least twenty-one days. Id. at 31. On August 18, 2026, Plaintiff notified the Court that class counsel had complied with the order directing notice. Pl.’s Notice of Compliance, Doc. 182. After twenty-one days, no objections had been filed. Id. at 3. DISCUSSION Rule 23 provides that “[i]n a certified class action, the court may award reasonable attorney’s fees and nontaxable costs that are authorized by law or by the parties’ agreement.” Fed. R. Civ. P. 23(h). Under the Settlement Agreement, “[t]he Parties agree that, subject to Court approval, Attorneys’ Fees, costs, and expenses, will be paid by State Farm in an amount approved

by the Court, but not to exceed $4,250,000.” Settlement Agreement ¶ 12.2. The amount would be paid separately and in addition to the $20,925,000.00 settlement fund. Id. The parties also agreed that, subject to the approval of the Court, Defendants “shall pay [Named] Plaintiff a service of incentive award of $25,000.” Id. ¶ 12.5. Fees were only negotiated after the parties had agreed on the substantive terms of the Settlement Agreement. Mot., Doc. 170 at 7. In the Motion, Plaintiff seeks an award of $4,250,000.00 and $25,000.00 for class counsel and Named Plaintiff, respectively. Id.; Pl.’s Suppl. Mot., Doc. 181. The Court will address each award request in turn. I. The Court will approve Plaintiff’s requested attorneys’ fees and costs.

Since class counsel seek the full amount allowed under the Settlement Agreement, the requested fee award is 20.31% of the aggregate cap of $20,925,000, or 16.9% of the total economic benefit to the class (once the settlement fund and attorneys’ fees caps are combined before calculating the percentage). The Court finds that this request meets the requirements of Rule 23(h) and is reasonable under the circumstances. A. Rule 23(h)(1) notice. Under Rule 23(h)(1), “[a] claim for an [attorneys’ fees] award must be made by motion . . . . Notice of the motion must be served on all parties and, for motions by class counsel, directed to class members in a reasonable manner.” Fed. R. Civ. P. 23(h)(1); see also 3 William B. Rubenstein, Newberg & Rubenstein on Class Actions § 8:22 (6th ed.). According to the Tenth Circuit, “‘the motion’ refers to ‘the motion that class counsel must file to make a claim for fees under Rule 23.’” Chieftain Royalty Co. v. SM Energy Co., 100 F.4th 1147, 1156–57 (10th Cir. 2024) (failing to provide class members with notice of renewed motion for attorneys’ fees “contravened” Rule 23(h)). Notice that the motion will be made available is insufficient. See id. at 1158 n.15 (collecting

cases indicating that fee request itself should be filed prior to objection deadline); see also Fed. R. Civ. P. 23 2003 amend. advisory comm. note (“Because members of the class have an interest in the arrangements for payment of class counsel whether that payment comes from the class fund or is made directly by another party, notice is required in all instances.”). Initially, class counsel notified class members and officials via Class Action Fairness Act notices that they intended to seek up to $4,250,000 in the emailed and mailed notices. See Pl.’s Mot. to Approve Settlement 26, Doc. 169-1. A notification that class counsel will seek “up to” $4,250,000 is different from a notification that class counsel will seek the full $4,250,000. And the initial notice did not provide details as to the time and expenses dedicated to the class action. 5

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Dana Schwartz, on behalf of herself and all others similarly situated v. State Farm Mutual Automobile Insurance Company, State Farm Fire and Casualty Company, and State Farm General Insurance Company, (D.N.M. 2026).

Dana Schwartz, on behalf of herself and all others similarly situated v. State Farm Mutual Automobile Insurance Company, State Farm Fire and Casualty Company, and State Farm General Insurance Company (Dana Schwartz, on behalf of herself and all others similarly situated v. State Farm Mutual Automobile Insurance Company, State Farm Fire and Casualty Company, and State Farm General Insurance Company) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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