## Facts

- John and Sharon Mirabal bought an automobile on credit through a dealer and financing company, using a 36-month installment contract.
- The disclosure statement understated the transaction’s annual percentage rate, leading the Mirabals to sue under the Truth in Lending Act (TILA) and two Illinois statutes.
- The district court initially found multiple TILA violations and entered a damages judgment exceeding $8,000.
- On an earlier appeal, the Seventh Circuit limited recovery to $2,000 plus costs and attorney’s fees and rejected liability under the Illinois statutes.
- On remand to set fees, plaintiffs’ counsel claimed 350 hours of work (120 in the district court and 230 on appeal) and asserted that defense counsel were paid more than $30,000.
- The district court awarded $690.10 in costs and $2,000 in attorney’s fees.
- Plaintiffs’ counsel appealed, arguing the fee award was an abuse of discretion.

## Issues

1. Whether the district court abused its discretion in awarding $2,000 in attorney’s fees (plus $690.10 in costs) under TILA where counsel claimed 350 hours of work and compared the request to alleged defense expenditures.

## Decision

- The Seventh Circuit affirmed the district court’s award of $2,000 in attorney’s fees and $690.10 in costs.
- The court held the district judge had broad discretion to assess the reasonable value and necessity of the services performed.
- The court declined to treat counsel’s claimed hours or the alleged amount paid to defense counsel as controlling.
- The court treated the modest recovery and small-dollar consumer transaction as relevant context in evaluating reasonableness.
- A dissent would have found the award unreasonably low in light of TILA’s enforcement purposes.

## Legal Principles

- Attorney-fee awards under TILA are reviewed for abuse of discretion, with substantial deference to the trial court’s evaluation of the lawyer’s work and the demands of the case.
- Although TILA mandates a reasonable fee for a prevailing consumer, courts may reduce requested fees based on the reasonable necessity of the time claimed and the results obtained.
- A fee award need not mirror defense counsel’s expenditures and need not be driven solely by the number of hours asserted by prevailing counsel.
- The size of the underlying transaction and the limited recovery after appellate review may be considered when fixing a reasonable fee.

## Conclusion

The Seventh Circuit held that the district court acted within its discretion in awarding $2,000 in attorney’s fees and costs after a small-dollar TILA recovery was reduced on appeal, rejecting the argument that claimed hours or defense spending required a higher fee.


Mirabal v. Gen. Motors Acceptance Corp., 576 F.2d 729 (7th Cir. 1978)