Scudder v. Equifax Information Services, LLC

CourtDistrict Court, M.D. Florida
DecidedSeptember 30, 2025
Docket3:21-cv-00741
StatusUnknown

This text of Scudder v. Equifax Information Services, LLC (Scudder v. Equifax Information Services, LLC) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Scudder v. Equifax Information Services, LLC, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA JACKSONVILLE DIVISION

BRUCE SCUDDER,

Plaintiff, Case No. 3:21-cv-741-TJC-SJH v.

SOFI LENDING CORP, LVNV FUNDING, LLC, and RESURGENT CAPITAL SERVICES L.P.,

Defendants.

ORDER Plaintiff Bruce Scudder went to trial against three Defendants under three consumer protection statutes. A jury found each Defendant violated at least one statute, but when it came to awarding damages, the jury’s verdict was not straightforward, making the award of attorney’s fees more difficult. Scudder sued all three Defendants, SoFi Lending Corp, LVNV Funding, LLC, and Resurgent Capital Services L.P., under the Fair Credit Reporting Act, and the jury found all three defendants were negligent. See (Doc. 189). It awarded Scudder $30,000.00 in actual damages on the FCRA claim against SoFi, but did not award actual damages against LVNV or Resurgent, and did not award any punitive damages. Id. Scudder sued LVNV and Resurgent under the Fair Debt Collection Practices Act and Florida Consumer Collections Practices Act. See (Doc. 1). With respect to the FDCPA, the jury found LVNV and Resurgent violated the statute, but did not award any damages. (Doc. 189).

With respect to the FCCPA, the jury found that LVNV and Resurgent violated the statute, did not award Scudder any actual damages, but did award $30,000.00 in punitive damages ($15,000.00 each against LVNV and Resurgent). Possible awards under all three claims could have included

statutory damages, but Scudder elected to waive any claim for statutory damages. See id., (Doc. 184 at 22–31.)1 Scudder requests an award of fees under the fee-shifting provisions of the FCRA, FDCPA, and the FCCPA, arguing the award of fees is proper because he

prevailed on every claim he pressed at trial. Scudder is seeking $465,257.00 in attorney’s fees (Doc. 229), and $33,195.102 in costs (Doc. 228). Defendants oppose Scudder’s motions, arguing both over the entitlement to attorney’s fees and amount of the fees and costs. (Docs. 249, 251). LVNV and

Resurgent argue that Scudder cannot recover fees from them under any of the statutes. (Doc. 249 at 6–14). SoFi argues Scudder is not entitled to fees because it is actually the prevailing party under the one-satisfaction rule. (Doc. 251 at

1 The Court uses the CM/ECF pagination when referring to the filings rather than the document pagination. 2 This is the amount on the Bill of Costs. (Doc. 228-1). The itemized amount is $100 more, for a total of $33,295.10. (Doc. 228-2). 3–4). If the Court disagrees, SoFi argues that the Court should reduce the requested fees for various reasons. Id. at 4–23.

I. ENTITLEMENT TO FEES “In the United States, parties are ordinarily required to bear their own attorney’s fees—the prevailing party is not entitled to collect from the loser.” Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Hum. Res., 532

U.S. 598, 602 (2001). Under this “American Rule,” a court may not award attorney’s fees to a prevailing party “absent explicit statutory authority.” Id. (quoting Key Tronic Corp. v. United States, 511 U.S. 809, 819 (1994)). To qualify as a “prevailing party,” a litigant must obtain some sort of

judicially sanctioned relief that materially alters the relationship between the parties. Tejero v. Portfolio Recovery Assocs., L.L.C., 993 F.3d 393, 397 (5th Cir. 2021) (citing Buckhannon, 532 U.S. at 604–05). The party seeking a post- judgment award of attorney’s fees bears the burden of establishing entitlement

to them. See Hensley v. Eckerhart, 461 U.S. 424, 437 (1983) (“the fee applicant bears the burden of establishing entitlement to an award and documenting the appropriate hours expended and hourly rates.”). The FCRA, FDCPA, and FCCPA each authorize an award of reasonable

attorney’s fees. See 15 U.S.C. §§ 1681o, 1682k(a)(3), and FLA. STAT. § 559.77(2). However, there are variations. The Court takes each in turn. A. FCRA The award of attorney’s fees based on a negligent FCRA violation is covered in § 1681o3, which states in part:

(a) In general

Any person who is negligent in failing to comply with any requirement imposed under this subchapter with respect to any consumer is liable to that consumer in an amount equal to the sum of—

(1) any actual damages sustained by the consumer as a result of the failure; and

(2) in the case of any successful action to enforce any liability under this section, the costs of the action together with reasonable attorney’s fees as determined by the court.

15 U.S.C. § 1681o. Attorney’s fees are available only in the case of a “successful action to enforce any liability under this section.” Nagle v. Experian Info. Sols., Inc., 297 F.3d 1305, 1306 (11th Cir. 2002). In Nagle, the Eleventh Circuit explained that a plaintiff who won a jury verdict on liability, but failed to obtain any actual or punitive damages, was not “successful” in enforcing “any liability under this section.” Id. Here, the jury found all three defendants negligently violated the FCRA

3 Scudder bases his FCRA entitlement argument on 15 U.S.C. § 1681n, but this provision is for “civil liability for willful noncompliance.” The jury only found that the defendants’ violations were negligent, not willful. Thus, the Court’s analysis is under § 1681o: civil liability for negligent noncompliance. but awarded Scudder damages only against SoFi. Accordingly, because there was a successful action to enforce liability only as to SoFi, Scudder is entitled

to attorney’s fees only as to SoFi. In addition to other objections, SoFi requested fees be apportioned among all defendants, but that is counter to the logic and holding of Nagle. See (Doc. 251 at 22–23). Because the Court has already rejected SoFi’s argument based on the one-satisfaction rule, it need not address

it here. See (Docs. 222, 225). B. FDCPA Like the FCRA, the FDCPA authorizes an award to any “successful” plaintiff of the costs of the action and a “reasonable attorney’s fee as determined

by the court.” 15 U.S.C. § 1692k(a)(3). However, a plaintiff must be awarded actual or statutory damages to be successful. See §§ 1692k(a)(1)–(a)(2)(A). Even a plaintiff who “wins a nominal amount of statutory damages” is entitled to fees under FDCPA’s fee-shifting provision. Thornton v. Wolpoff & Abramson, L.L.P.,

312 F. App’x 161, 164 (11th Cir. 2008) (per curiam) (citing Nagle, 297 F.3d at 1307). “The difference between zero dollars and one dollar is the difference between an unsuccessful action and a successful action.” Id. The jury found that LVNV and Resurgent violated the FDCPA, but it did

not award actual damages, and Scudder waived his right to statutory damages. Therefore, Scudder was not a “successful” plaintiff entitled to an award of attorney’s fees under the FDCPA. C. FCCPA The civil remedies provision of the FCCPA states in relevant part:

Any person who fails to comply with any provision of s.

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Related

Kathleen Thornton v. Wolpoff & Abramson, L.L.P.
312 F. App'x 161 (Eleventh Circuit, 2008)
Dillard v. City of Greensboro
213 F.3d 1347 (Eleventh Circuit, 2000)
Nagle v. Experian Information Solutions, Inc.
297 F.3d 1305 (Eleventh Circuit, 2002)
Bivins v. Wrap It Up, Inc.
548 F.3d 1348 (Eleventh Circuit, 2008)
Hensley v. Eckerhart
461 U.S. 424 (Supreme Court, 1983)
Blanchard v. Bergeron
489 U.S. 87 (Supreme Court, 1989)
Loranger v. Stierheim
10 F.3d 776 (Eleventh Circuit, 1994)
Key Tronic Corp. v. United States
511 U.S. 809 (Supreme Court, 1994)
Tejero v. Portfolio Recovery Assoc
993 F.3d 393 (Fifth Circuit, 2021)
Peters v. Collision Clinics International Inc.
404 So. 2d 116 (District Court of Appeal of Florida, 1981)
In Re: Blue Cross Blue Shield Antitrust Litigation
85 F.4th 1070 (Eleventh Circuit, 2023)

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