## Facts

- Richard L. Sheffer sued multiple defendants, including Sears, asserting violations of the Fair Credit Reporting Act (FCRA) and related state-law claims arising from allegedly inaccurate credit reporting.
- After a jury trial, the jury found Sears liable on the FCRA claim and awarded Sheffer $1,000 in actual damages; it awarded no punitive damages.
- Sheffer moved for attorneys’ fees and costs under 15 U.S.C. § 1681o(a)(2) and Federal Rule of Civil Procedure 54(d), seeking $126,543.33 in fees and $14,010.75 in costs for work by three law firms.
- Sears opposed the petition, arguing the request was unreasonable due to excessive and duplicative time, clerical work billed as legal work, inadequate documentation, unreasonable rates, improper expenses, and Sheffer’s limited success compared to his trial demand (including a claim for substantially higher damages).

## Issues

1. Whether Sheffer qualified as a prevailing party entitled to attorneys’ fees and costs under the FCRA.
2. What fee award was reasonable under the lodestar method (reasonable hours × reasonable rate), given objections to hours, rates, and documentation.
3. Whether, and to what extent, the fee and cost award should be reduced to reflect Sheffer’s limited degree of success, including the small damages award and the denial of punitive damages.
4. Which claimed litigation expenses were recoverable as costs and which should be disallowed as unnecessary, unsupported, or non-taxable.

## Decision

- The court held that Sheffer was a prevailing party on the FCRA claim and was entitled to reasonable attorneys’ fees and costs from Sears.
- The court applied the lodestar framework and reduced the request by excluding or cutting hours that were unreasonable, duplicative, clerical, insufficiently documented, or not tied to the successful claim.
- The court reviewed the requested hourly rates against prevailing local market rates and reduced rates where not adequately supported or not reasonable for the case and counsel’s role.
- The court allowed recoverable costs but reduced requested expenses where they were inadequately documented, not reasonably necessary, or otherwise not properly chargeable.
- After itemized reductions, the court imposed an additional across-the-board reduction to account for Sheffer’s limited success, granting the motion in part and denying it in part.

## Legal Principles

- Under 15 U.S.C. § 1681o(a)(2), a prevailing plaintiff in an FCRA action may recover reasonable attorneys’ fees and costs.
- The lodestar method (reasonable hours multiplied by reasonable hourly rate) is the starting point for calculating statutory fee awards.
- The most important factor in determining a reasonable fee is the degree of success obtained; a court may substantially reduce fees where the plaintiff achieved only partial or limited success.
- Clerical or administrative tasks are not compensable at attorney rates and may be excluded as overhead.
- A court may reduce fees and costs for inefficiency, duplication, vagueness, inadequate documentation, and expenses not reasonably necessary to the outcome.

## Conclusion

The court recognized Sheffer’s prevailing-party status under the FCRA but sharply reduced the requested fees and costs through lodestar cuts and a further reduction tied to the limited $1,000 recovery and lack of punitive damages, awarding only the amount the court deemed reasonable for the results obtained.


Sheffer v. Experian Info. Sols., Inc., 290 F. Supp. 2d 538 (E.D. Pa. 2003)