Roneca Echols v. Express Auto, Inc.

CourtCourt of Appeals for the Sixth Circuit
DecidedMay 25, 2021
Docket20-1707
StatusUnpublished

This text of Roneca Echols v. Express Auto, Inc. (Roneca Echols v. Express Auto, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Roneca Echols v. Express Auto, Inc., (6th Cir. 2021).

Opinion

NOT RECOMMENDED FOR PUBLICATION File Name: 21a0252n.06

Nos. 20-1706/1707

UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED RONECA ECHOLS, ) May 25, 2021 ) DEBORAH S. HUNT, Clerk Plaintiff-Appellee, ) ) v. ) ON APPEAL FROM THE ) UNITED STATES DISTRICT EXPRESS AUTO, INC., ) COURT FOR THE WESTERN ) DISTRICT OF MICHIGAN Defendant-Appellant. ) )

BEFORE: WHITE, NALBANDIAN, and READLER, Circuit Judges.

CHAD A. READLER, Circuit Judge. Express Auto sells and finances the sale of used

motor vehicles. Roneca Echols, an aspiring customer, brought an action against Express asserting

violations of the Equal Credit Opportunity Act. The parties settled for $10,000. Echols then

sought attorney’s fees and costs, the issues that eventually gave rise to this appeal. The district

court awarded Echols $76,795 in attorney’s fees and $2,125 in non-taxable costs. Seeing no abuse

of discretion in that award, we affirm.

I.

On several occasions, Roneca Echols failed to secure financing through Express to

purchase a motor vehicle Express offered for sale. Those failures prompted Echols to file suit

alleging that Express violated the Equal Credit Opportunity Act (ECOA) in two respects: one by

failing to properly notify Echols that she was denied credit, and another by allegedly discriminating

against Echols based on her marital status. See 15 U.S.C. § 1691 et seq. The filing precipitated Case Nos. 20-1706/1707, Echols v. Express Auto, Inc.

some early sparring between the parties, with Echols unsuccessfully seeking a lofty settlement

award and Express being less than forthcoming during discovery. Ultimately, the parties reached

a settlement. Express agreed to pay Echols $10,000 in exchange for a release from the claims

asserted in the complaint.

Following the entry of a consent judgment, the district court permitted Echols to petition

for attorney’s fees in accordance with the ECOA’s attorney’s fees provision. See 15 U.S.C.

§ 1691e(d); Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Hum. Res., 532 U.S.

598, 604 (2001) (noting that a prevailing party includes one who prevails through a settlement by

entry of a consent decree). Echols sought attorney’s fees and non-taxable costs totaling $82,395.

Express responded primarily by arguing that the requested amount was grossly disproportional to

the recovery, and that the fee award should be limited to one third of the settlement amount, which

Express assumed (incorrectly) was the fee arrangement Echols had with her counsel. Express also

argued that the proposed hourly rates were too high and that the hours claimed were excessive. At

the close of a hearing to address the fees petition, the district court explained that Express’s primary

argument was “troubling” in that it “clearly ignore[d] the statutory fee shifting provisions and the

purposes behind these kinds of statutes,” as well as binding caselaw. The court also criticized

Express for asserting, contrary to Supreme Court precedent, that paralegal time was categorically

unable to be compensated, an objection Express then withdrew. After reducing one of Echols’s

attorneys requested hourly rate, the district court found that the fees sought were reasonable and

awarded Echols $76,795 in attorney’s fees and $2,125 in non-taxable costs. In a timely appeal,

Express argues that the district court abused its discretion by failing to adequately explain its fees

award and by awarding non-taxable costs. (The district court denied a second motion seeking

taxable costs pursuant to 28 U.S.C. § 1920, an issue not raised in this appeal.)

-2- Case Nos. 20-1706/1707, Echols v. Express Auto, Inc.

II.

One hallmark of the American judicial system is the practice of parties to a lawsuit bearing

their own attorney’s fees and costs. In some settings, however, Congress has altered that traditional

practice by statute. See Hensley v. Eckerhart, 461 U.S. 424, 429 (1983) (citing Alyeska Pipeline

Serv. Co. v. Wilderness Soc’y, 421 U.S. 240, 247 (1975)). One such example is § 1691e(d) of the

ECOA. There, Congress instructed that when a party prevails under specific sections of the ECOA,

“the costs of the action, together with a reasonable attorney’s fee as determined by the court, shall

be added to any damages awarded by the court under such subsection.” 15 U.S.C. § 1691e(d).

A perhaps more well-known example of Congress’s altering of the custom of bearing one’s

own legal fees is 42 U.S.C. § 1988(b), through which Congress authorized district courts to award

reasonable attorney’s fees to a prevailing party in various forms of civil rights litigation. Most

federal fee-shifting statutes mirror the language of § 1988(b)—including, in many respects, the

ECOA. Compare 42 U.S.C. § 1988(b) (authorizing the recovery of “a reasonable attorney’s fee”),

with 15 U.S.C. § 1691e(d) (authorizing the recovery of “a reasonable attorney’s fee”). As a result,

courts have often borrowed from § 1988(b)’s jurisprudence when analyzing related fee-shifting

statutes. See Pennsylvania v. Del. Valley Citizens’ Council for Clean Air, 478 U.S. 546, 562 (1986)

(noting there are over 100 separate statutes providing for attorney’s fees, nearly all of which require

that the attorney’s fee must be “reasonable”); Hensley, 461 U.S. at 433 n.7 (explaining that “the

standards set forth in [Hensley] are generally applicable in all cases in which Congress has

authorized an award of fees to a ‘prevailing party’”). We see no reason to deviate from that

approach in applying § 1691e(d).

Following the lead of cases interpreting § 1988(b), we note the party seeking an attorney’s

fees award under § 1988(b) bears the burden to demonstrate why its fee request is reasonable. See

-3- Case Nos. 20-1706/1707, Echols v. Express Auto, Inc.

Hensley, 461 U.S. at 437. To do so, a fee petitioner must submit documentation “supporting the

hours worked and rates claimed.” Id. at 433. To measure whether a party’s attorney’s fees request

is reasonable, a district court customarily begins by calculating the party’s “lodestar” amount. City

of Riverside v. Rivera, 477 U.S. 561, 568 (1986). The lodestar amount is “the number of hours

reasonably expended on the litigation multiplied by a reasonable hourly rate,” which courts

presume to be a reasonable fee award. Id. (quoting Hensley, 461 U.S. at 433). The lodestar

calculation’s goal is to provide an amount adequate to attract competent counsel while avoiding a

windfall for those counsel. See Blum v.

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Related

Alyeska Pipeline Service Co. v. Wilderness Society
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Hensley v. Eckerhart
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Blum v. Stenson
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City of Riverside v. Rivera
477 U.S. 561 (Supreme Court, 1986)
Blanchard v. Bergeron
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Missouri v. Jenkins Ex Rel. Agyei
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65 F.3d 532 (Sixth Circuit, 1995)
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