Singh v. Experian Information Solutions
Manpreet Singh v. Experian Information Solutions, Inc.; Trans Union, LLC; and Discover Bank
- Katherine Menendez
- 0:25-cv-00378
- U.S. District Court · District of Minnesota
- 16
In Singh v. Experian, Judge Menendez granted in part Plaintiff Manpreet Singh's fee motion, awarding $27,886.25 total against Midland Credit Management.
Plaintiffs who have won consumer credit cases (particularly Fair Credit Reporting Act or Fair Debt Collection Practices Act claims) and their attorneys seeking fee awards, and defendants such as debt collectors and credit reporting agencies who may face fee liability after settlements or judgments in such cases.
What happened
In Manpreet Singh v. Experian Information Solutions, Inc., Trans Union, LLC, and Discover Bank (with Midland Credit Management, Inc. as the relevant defendant for this motion), Plaintiff Manpreet Singh sued multiple consumer reporting agencies and financial institutions under the Fair Credit Reporting Act, alleging they wrongly placed debts and contact information on his credit report that predated his arrival in the United States. Midland Credit Management settled with Singh by offering him $7,500 plus reasonable attorneys' fees and costs, with the fee amount to be determined by the court if the parties could not agree. The parties negotiated for roughly six weeks but could not reach an agreement, leading Singh to file this motion seeking $28,712.50 in total (attorneys' fees, costs, and the $7,500 payment).
The central dispute was whether Singh's attorney, Yitzchak Zelman, was entitled to his requested hourly rate of $425 and his claimed hours. Midland argued the rate was too high, the hours excessive, and that some work billed was not specific to claims against Midland. The court evaluated these arguments using the 'lodestar' method — multiplying the number of hours reasonably spent by a reasonable hourly rate — and also considered whether Midland was responsible for all shared filing costs or only a proportional share.
Judge Menendez granted the motion in part, finding $425 per hour reasonable based on local market data, practitioner declarations, and comparable cases in the District of Minnesota. She upheld most of the claimed hours but deducted time spent on purely administrative tasks (0.5 attorney hours and 1.0 paralegal hours) and time spent correcting an oversight (0.2 hours). She declined to award fees for reply-brief preparation because that request was improperly raised for the first time in the reply, though she noted Singh may file a supplemental motion. On costs, she held Midland responsible for only 25% of the initial filing fee and pro hac vice fee, since those were shared among multiple defendants. The final award is $27,886.25, comprising the $7,500 offer-of-judgment payment, $20,175 in attorneys' fees, and $211.25 in costs.
The detailed version
- Singh v. Experian Information Solutions · No. 0:25-cv-00378
- Katherine Menendez
- Dec. 9, 2025
Background
Plaintiff Manpreet Singh filed this lawsuit in January 2025 against multiple defendants — Midland Credit Management, Inc. ("Midland"), Equifax Information Services LLC, Experian Information Solutions, Inc., Trans Union, LLC, and Discover Bank — alleging violations of the Fair Credit Reporting Act ("FCRA"), 15 U.S.C. §§ 1681 et seq. Singh, who immigrated to the United States in 2023 and received a Social Security number in 2024, alleged that defendants incorrectly attributed to him debts and contact information that predated his arrival in the country. Equifax was subsequently dismissed after settling. Midland made a Rule 68 offer of judgment (a procedural mechanism allowing a defendant to formally offer to settle a case, which, if accepted, results in a court judgment) for $7,500 plus reasonable attorneys' fees and costs limited to claims against Midland, with the fee amount to be agreed upon by the parties or determined by the court.
Singh accepted the offer. Negotiations over fees between Singh's attorney, Yitzchak Zelman, and Midland's attorney broke down after roughly six weeks. Mr. Zelman sought $22,500 (including the $7,500 payment) as a bottom-line settlement figure; Midland countered at $10,256.25 in fees and costs. Singh then filed this motion seeking a total award of $28,712.50, comprising $20,622.50 in attorneys' fees, $590 in costs, and the $7,500 judgment payment.
Legal Standard
The court applied the lodestar method — multiplying the number of hours reasonably expended by a reasonable hourly rate — which carries a strong presumption of reasonableness. The party seeking fees bears the burden of showing both that the requested hourly rate aligns with prevailing community rates for comparable work and that the claimed hours were reasonably expended. Courts may exercise broad discretion and use estimates rather than achieving "auditing perfection."
Reasonable Hourly Rate
Singh requested $425 per hour for Mr. Zelman's work and $175 per hour for paralegal work. Midland did not contest the paralegal rate. On the attorney rate, the court found $425 per hour reasonable, citing:
- Mr. Zelman's declaration describing his training and experience in consumer law; - A calculation using the United States Consumer Law Attorney Fee Survey Report, adjusted for inflation via the Bureau of Labor Statistics's CPI Inflation Calculator, placing the average Twin Cities consumer law attorney rate at $440 per hour for someone of comparable experience; - A supporting declaration from local consumer law attorney Ryan Peterson; - Recent District of Minnesota precedent approving $425 per hour for an attorney of comparable experience in a related consumer-credit case.
The court distinguished Midland's reliance on Woodward v. Credit Service International Corporation, where the court had approved only $350 per hour, noting that Woodward involved a simpler case, far less experience on counsel's part, and no supporting rate declarations from local practitioners.
Reasonableness of Hours — Case in Chief
Mr. Zelman claimed 39.3 attorney hours and 2 paralegal hours on the case in chief, reflected in 69 billing entries over 11 months. The court found this topline figure reasonable. Midland challenged four categories of billing:
Administrative Tasks Midland challenged 10 entries as administrative and therefore non-compensable or warranting a reduced rate. The court agreed in part: entries combining substantive and minor administrative tasks were allowed; purely administrative entries (such as reviewing electronic filing confirmations, sending out summonses for service, and providing credit card information for filing fees) were disallowed. The court deducted 0.5 attorney hours and 1.0 paralegal hours on this basis.
Unnecessary Work Midland challenged 0.2 hours spent correcting an oversight (re-circulating an email that had omitted Midland's attorney). The court agreed this did not reflect proper billing judgment and deducted those hours. Midland also challenged 1.2 hours Mr. Zelman spent disputing Midland's demand for billing records during fee negotiations. The court declined to deduct those hours, relying on Berscheid v. Experian Info. Solutions, Inc., a prior District of Minnesota case against Midland involving similar circumstances, which held that attorneys are not required to produce billing records as a prerequisite to filing a fee petition.
Work Attributable to Other Co-Defendants Midland argued that some claimed hours reflected work on claims against all remaining defendants, not just Midland, and sought to reduce its share to 25% of the total. The court rejected this argument because Midland failed to identify specifically which hours it challenged, and Mr. Zelman attested as an officer of the court that he had already excluded time attributable solely to other defendants from his billing records. Midland offered no evidence to disprove that attestation.
Co-Counsel Communications Midland argued that 1.8 hours of co-counsel communications were non-compensable due to insufficient specificity. The court disagreed, finding the entries sufficiently specific and the time (averaging under ten minutes per month over eleven months) reasonable. It also noted that local counsel was not seeking any fees, eliminating double-billing concerns.
Hours Expended on Fee Petition and Reply
The court allowed 8.4 hours spent preparing the fee petition as reasonable and uncontested. It declined, however, to award fees for 7.9 hours spent preparing the reply brief, because that request was raised for the first time in the reply itself — which, under District of Minnesota Local Rule 7.1(c)(3)(B), cannot introduce new grounds for relief. The court noted that Singh may file a supplemental motion for those fees.
Further Reduction for Negotiating Conduct
Midland sought a further reduction based on what it characterized as Mr. Zelman's unreasonable positions during fee negotiations. The court declined, finding that Mr. Zelman promptly made a settlement offer, stayed in communication, followed up, and ultimately provided billing records. His conduct did not rise to the level of obstruction or overreach seen in prior cases warranting a fee reduction.
Costs
Singh sought $590 in costs: a $405 initial filing fee, $85 for serving Midland, and a $100 pro hac vice (temporary admission of an out-of-state attorney) filing fee. The court held Midland responsible for the full $85 service fee but only 25% of the $405 filing fee and 25% of the $100 pro hac vice fee, reflecting that those costs were shared across four remaining defendants. Total costs awarded: $211.25.
Disposition
The court granted the motion in part. Midland is ordered to pay a total of $27,886.25, comprising the $7,500 offer-of-judgment payment, $20,175 in attorneys' fees, and $211.25 in costs. The court denied the portion of the motion seeking fees for the reply brief, but without prejudice to Singh filing a supplemental motion.
Read the full 16-page opinion on CourtListener, the free public archive maintained by the Free Law Project.