Jefferson v. General Motors LLC

CourtDistrict Court, W.D. Tennessee
DecidedAugust 19, 2025
Docket2:20-cv-02576
StatusUnknown

This text of Jefferson v. General Motors LLC (Jefferson v. General Motors LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jefferson v. General Motors LLC, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

RILLA JEFFERSON, on behalf of herself and Case No. 2:20-cv-02576-JPM-tmp all others similarly situated,

Plaintiff, v. GENERAL MOTORS LLC, Defendant. MARK RILEY, on behalf of himself and all Case No. 2:24-cv-02982-JPM others similarly situated,

Plaintiff, v. GENERAL MOTORS LLC, Defendant. ORDER GRANTING PLAINTIFF’S UNOPPOSED MOTION FOR ATTORNEY’S FEES AND EXPENSES AND SERVICE AWARDS TO PLAINTIFFS Before the Court is an Unopposed Motion for an Award of Attorney’s Fees and Expenses and Service Awards to the Plaintiffs, filed by Plaintiffs Rilla Jefferson (“Jefferson”) and Mark Riley (“Riley”), on behalf of themselves and all others similarly situated (collectively, “Plaintiffs” or the “Class”) on June 20, 2025. (ECF No. 206.) Plaintiffs report Defendant General Motors LLC (“Defendant” or “GM”) does not oppose the Motion to the extent it does not contradict the Parties’ Settlement Agreement. (Id. at PageID 2905.) Defendant has not filed any response to the Motion. For the reasons stated below, Plaintiffs’ Motion is GRANTED. I. BACKGROUND These cases constitute a consolidated class action against GM regarding allegedly defective transmission shifter assemblies in specified Class Vehicles for the two certified classes. Class Counsel has litigated the shift-to-park issue (the “STP Issue”) for over six years across multiple

jurisdictions and courts. (See ECF No. 206-1 at PageID 2914.) The Settlement Agreement provides for $500 cash payments to each Class Member. (Id.) There are 5,213 Class Members identified in GM’s Warranty Data with confirmed ownership of a Class Vehicle. (Id.) Class Members who paid out of pocket for repairs for the STP Issue can receive an additional reimbursement of up to $375. (Id. at PageID 2915.) The payments are either automatic or subject to a straightforward claim process based on the Class Member’s identifiability from the relevant GM dataset. (Id. at PageID 2914–15.) At the time of the filing of the Motion, the Class Administrator had received 3,551 claims. (See id. at PageID 2915.) There is no cap on the number of Class Members who can recover nor is the claim sum diluted by the number of claims. (Id.)

GM agrees to pay the Court-authorized awards “separate and apart from payments” to Plaintiffs. (Id. at PageID 2924.) Additionally, GM is paying the cost of the notice and administration of the claims process. (Id. at PageID 2923.) II. LEGAL STANDARD “In a certified class action, the court may award reasonable attorneys’ fees and nontaxable costs that are authorized by law or by the parties’ agreement.” Fed. R. Civ. P. 23(h). “The primary concern . . . is that the fee awarded be reasonable.” Reed v. Rhodes, 179 F.3d 453, 471 (6th Cir. 1999). “When awarding attorney’s fees in a class action, [the] court must make sure that counsel is fairly compensated for the amount of work done as well as for the results achieved.” Rawlings v. Prudential-Bache Props., Inc., 9 F.3d 513, 516 (6th Cir. 1993). The court must provide “a reasonably specific explanation for all aspects of a fee determination.” Freed v. Thomas, 137 F.4th 552, 560 (6th Cir. 2025) (quoting Perdue v. Kenny A. ex rel. Winn, 559 U.S. 542, 558 (2010)). “To properly calculate an attorneys’ fee award, the district court must start by multiplying

the ‘hours reasonably expended’ by ‘a reasonable hourly rate.’” Freed, 137 F.4th at 557 (quoting Hensley v. Eckerhart, 461 U.S. 424, 433 (1983)). This “lodestar” figure presumptively represents a reasonable fee. See id. at 560 (citing Murphy v. Smith, 583 U.S. 220, 227 (2018)). Generally, the reasonableness of the rates corresponds to the prevailing rates in the relevant community, focuses on the experience, training, and background of the individual attorneys, and is “defined as the rate that lawyers of comparable skill and experience can reasonably expect to command within the venue of the court of record.” Geier v. Sundquist, 372 F.3d 784, 791 (6th Cir. 2004) (citations omitted). Prior to any award of fees, “a district court must conclude that the fee applicant has sufficiently documented his time and hourly rate.” Keener v. Dep’t of Army, 136 F.R.D. 140, 146

(M.D. Tenn. 1991). The proof submitted “must be detailed enough for a district court to determine with a high degree of certainty that the time claimed was actually and reasonably spent.” Id. at 147. III. ANALYSIS Defendant does not oppose Plaintiffs’ Motion. (See ECF No. 206 at PageID 2905.) Therefore, the Court need only determine that the requested awards are reasonable and sufficiently supported by documentation provided by Plaintiffs. See Reed, 179 F.3d at 471; Keener, 136 F.R.D. at 146–47. A. Attorney’s Fees and Expenses Plaintiffs seek $2,035,000 in attorney’s fees and expenses for their Class Counsel. (ECF No. 206 at PageID 2905.) i. Attorney’s Fees

To determine the reasonableness of an award, courts often consider: (1) the value of the benefit rendered to the plaintiff class; (2) the value of the services on an hourly basis; (3) whether the services were undertaken on a contingent fee basis; (4) society’s stake in rewarding attorneys who produce such benefits in order to maintain an incentive to others; (5) the complexity of the litigation; and (6) the professional skill and standing of counsel involved on both sides. See Moulton v. U.S. Steel Corp., 581 F.3d 344, 352 (6th Cir. 2009) (quoting Bowling v. Pfizer, Inc., 102 F.3d 777, 780 (6th Cir. 1996)). The Court finds that all the factors support the requested award. See id. First, the result obtained on behalf of Plaintiffs is substantial in the aggregate and guarantees cash payments for Plaintiffs without the additional expense and risk associated with proceeding to trial. (ECF No. 206-1 at PageID 2914–15); see id. at 352. The fee award structure also does not impact fee recovery. (ECF No. 206-1 at PageID 2924.) Second, the award reflects the reasonable value of Class Counsel’s services in this matter. See Moulton, 581 F.3d at 352; Rawlings, 9 F.3d at 516. Class Counsel reports 2,283.6 attorney and professional staff hours for extensive and multifaceted litigation efforts for more than six years. (ECF No. 206-1 at PageID 2925.) Plaintiffs provide sufficient evidence to confirm the number and reasonableness of the hours claimed. (See Lemberg Decl.; Screen Decl.; Lafferty Decl.); Keener, 136 F.R.D. at 146–47. Class Counsel’s requested hourly rates, (see ECF No. 206- 1 at PageID 2927),1 fall within the prevailing market rates for attorneys of comparable experience in complex class action litigation, see, e.g., Robles v. Comtrak Logistics, Inc., No. 2:15-cv-02228, 2022 WL 17672639, at *11 (W.D. Tenn. Dec. 14, 2022) (finding counsel’s fee request reasonable where hourly rates ranged between $625 and $1200), and have been found reasonable by other

courts, see, e.g., Guthrie v. Mazda Motor of Am., Inc., No. 8:22-cv-01055 (C.D. Cal.) (ECF Nos. 121-1 & 167) (awarding attorney’s fees and expenses in automotive defect class action settlement where hourly rates for Lemberg Law attorneys were between $550 and $900). Class Counsel’s requested multiplier of 1.35 also falls within the range of lodestar multipliers applied in contingent fee cases. See Jones v. Varsity Brands, LLC, No. 2:20-cv-02892, 2024 WL 5010412, at *9 (W.D. Tenn.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Bowling v. Pfizer, Inc.
102 F.3d 777 (Sixth Circuit, 1996)
Moulton v. United States Steel Corp.
581 F.3d 344 (Sixth Circuit, 2009)
Geier v. Sundquist
372 F.3d 784 (Sixth Circuit, 2004)
Murphy v. Smith
583 U.S. 220 (Supreme Court, 2018)
Perdue v. Kenny A. ex rel. Winn
176 L. Ed. 2d 494 (Supreme Court, 2010)
Reed v. Rhodes
179 F.3d 453 (Sixth Circuit, 1999)
Keener v. Department of Army
136 F.R.D. 140 (M.D. Tennessee, 1991)

Cite This Page — Counsel Stack

Bluebook (online)
Jefferson v. General Motors LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jefferson-v-general-motors-llc-tnwd-2025.