## Facts

- Jeffrey Strange purchased a $346.21 window at a Home Depot store using a Home Depot credit card issued by Monogram Credit Card Bank of Georgia.
- After discovering the window was mislabeled and unusable, Strange returned it and believed the purchase had been credited.
- His November 1994 billing statement did not show a credit for the return.
- Following the statement’s dispute instructions, Strange sent a written billing-error notice to the designated address requesting correction.
- Neither the merchant nor the card issuer responded; subsequent statements continued to reflect the disputed charge.
- Strange sent a second written notice; again there was no response, and the disputed amount remained on later statements.
- Strange sued under the Truth in Lending Act (TILA), alleging failures to correct the billing error and failures to acknowledge, investigate, and resolve the dispute as required by 15 U.S.C. § 1666, including continued collection efforts and finance charges.
- The disputed billing generated a finance charge of $27.36.

## Issues

1. Whether TILA’s civil-liability provision, 15 U.S.C. § 1640(a)(2)(A), permits separate statutory-damages awards for multiple billing-error handling failures arising from the same disputed transaction, or instead limits recovery to a single statutory-damages award per action.
2. Whether the district court abused its discretion under 15 U.S.C. § 1640(a)(3) by awarding $3,000 in attorney’s fees after the plaintiff requested $21,743.75 based on 123 hours of work.

## Decision

- The Seventh Circuit affirmed the judgment.
- The court held TILA does not authorize multiple statutory-damages recoveries “for each and every violation” arising from the same billing-error dispute in an individual action involving an open-end credit plan.
- The court upheld the statutory-damages award of $54.72, calculated as twice the finance charge ($27.36 × 2).
- The court held the district court did not abuse its discretion in reducing requested attorney’s fees to $3,000 as unreasonable given the simplicity of the matter and the results obtained.

## Legal Principles

- In an individual action under TILA involving an open-end consumer credit plan, § 1640(a)(2)(A) provides a single statutory-damages recovery per action for the disputed transaction, rather than separate awards for each distinct statutory misstep in handling the same billing error.
- Statutory damages in this setting may be calculated by reference to twice the finance charge, subject to TILA’s minimum and maximum limits.
- Under § 1640(a)(3), a prevailing consumer is entitled to a “reasonable” attorney’s fee, but the district court has broad discretion to reduce a request that reflects excessive hours relative to the litigation’s complexity and outcome.
- Appellate review of a TILA fee award is for abuse of discretion, and substantial reductions are permissible when supported by reasonableness findings.

## Conclusion

The court held that TILA statutory damages for a single credit-card billing-error dispute are not multiplied by counting each separate handling failure, and it upheld both the twice-finance-charge damages award and a sharply reduced attorney’s-fee award as within the district court’s discretion.


Strange v. Monogram Credit Card Bank of Ga., 129 F.3d 943 (7th Cir. 1997)