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 Manpreet Singh v. Experian Information Solutions, Inc.; Trans Union, LLC; and Discover Bank, Judge Menendez granted in part Plaintiff Manpreet Singh's motion for attorneys' fees and costs, awarding a total of $27,886.25 (including a previously agreed $7,500 payment) against Defendant Midland Credit Management, Inc. under the Fair Credit Reporting Act.
Consumers who have brought claims under the Fair Credit Reporting Act (FCRA) and their attorneys who seek fee awards after settling or obtaining judgment against debt collectors or credit reporting entities, particularly in the District of Minnesota. Also relevant to attorneys who litigate fee disputes with Midland Credit Management, Inc.
What happened
In Manpreet Singh v. Experian Information Solutions, Inc.; Trans Union, LLC; and Discover Bank, filed in the District of Minnesota, Plaintiff Manpreet Singh sued multiple consumer reporting agencies and financial institutions, including Midland Credit Management, Inc. ('Midland'), alleging they violated the Fair Credit Reporting Act ('FCRA') by placing inaccurate information on his credit report — including debts and contact details predating his 2023 arrival in the United States. Singh accepted a settlement offer from Midland that included $7,500 plus reasonable attorneys' fees and costs to be determined by the parties or, if they could not agree, by the Court. The parties were unable to agree, and Singh's attorney, Yitzchak Zelman, filed a motion asking the Court to award $28,712.50 total (including the $7,500).
Midland opposed the fee request on several grounds: it argued that Mr. Zelman's hourly rate of $425 was too high, that he billed too many hours, that some of the billed work related to defendants other than Midland, and that Mr. Zelman's negotiating behavior warranted a further reduction. The Court evaluated each argument, using the standard legal method of multiplying reasonable hours by a reasonable hourly rate (called the 'lodestar' method). The Court found $425 per hour reasonable based on survey data, inflation adjustments, comparable local cases, and a supporting declaration from another local consumer law attorney. The Court accepted most of the claimed hours but reduced the total by deducting time spent on purely administrative tasks (0.5 attorney hours and 1.0 paralegal hours) and time spent correcting a clerical mistake (0.2 hours). The Court declined to award fees for 7.9 hours spent preparing Singh's reply brief because that request was raised for the first time in the reply itself, giving Midland no opportunity to respond — though the Court noted Singh could file a separate motion for those fees.
Judge Menendez granted the motion in part, ordering Midland to pay Singh a total of $27,886.25, comprising the $7,500 settlement payment, $20,175 in attorneys' fees, and $211.25 in costs. On costs, the Court agreed with Midland that it should bear only 25 percent of the initial court filing fee and the attorney admission fee, since those costs were shared across multiple defendants. The Court rejected Midland's request for a further reduction based on Mr. Zelman's negotiating conduct, finding that he had acted in good faith throughout the fee dispute.
The detailed version
- Manpreet Singh v. Experian Information Solutions, Inc.; Trans Union, LLC; and Discover Bank, No. 0:25-cv-00378 (KMM/DJF)
- Katherine Menendez, United States District Judge
- December 9, 2025
Background
Plaintiff Manpreet Singh, who immigrated to the United States in 2023, sued Midland Credit Management, Inc. ('Midland'), Equifax Information Services, LLC, Experian Information Solutions, Inc., Trans Union, LLC, and Discover Bank under the Fair Credit Reporting Act ('FCRA'), 15 U.S.C. § 1681 et seq., alleging that Defendants incorrectly attributed debts and contact information predating his arrival to a Social Security number he received in 2024. Equifax was dismissed after settlement. Midland served a Federal Rule of Civil Procedure 68 offer of judgment — a procedural device allowing a defending party to offer to settle a case on specified terms; if the plaintiff accepts, judgment is entered accordingly — offering $7,500 plus 'reasonable attorneys' fees and costs' related to claims against Midland only, with the amount to be agreed upon or, failing agreement, determined by the Court. Singh accepted the offer. The parties could not agree on fees, and Singh's attorney, Yitzchak Zelman, filed a motion seeking $28,712.50 total ($20,622.50 in attorneys' fees, $590 in costs, plus the $7,500).
Legal Standard
The Court applied the 'lodestar' method — multiplying the number of hours reasonably expended by a reasonable hourly rate — as the starting point for determining a reasonable fee award. There is a strong presumption that the resulting lodestar figure is reasonable. The fee applicant bears the burden of establishing both a reasonable rate (with evidence beyond the attorney's own statements) and reasonable hours expended.
Hourly Rate ($425)
Mr. Zelman requested $425 per hour. The Court found this reasonable, relying on: (1) the United States Consumer Law Attorney Fee Survey Report, adjusted for inflation using the Bureau of Labor Statistics CPI Inflation Calculator, yielding an average of $440 for comparable attorneys in the Twin Cities; (2) a declaration from local consumer law attorney Ryan Peterson confirming the rate's reasonableness; and (3) a recent District of Minnesota decision approving $425 per hour for an attorney with comparable experience in a similar consumer protection case (Keating v. Frederick Debt Mgmt., LLC, 2025). The Court distinguished its own prior decision in Woodward v. Credit Service International Corporation, which approved only $350 per hour, because that case was simpler, resolved more quickly, involved fewer defendants, and the attorney there provided no supporting evidence of prevailing rates.
Hours — Case in Chief
Mr. Zelman claimed 39.3 attorney hours and 2 paralegal hours on the case in chief, across 69 billing entries over 11 months covering case intake, complaint drafting, discovery, Rule 26(f) reporting, and legal research. The Court found this reasonable as a topline figure. The Court then addressed Midland's four specific challenges:
1. Administrative tasks: The Court partially agreed. Entries that combined substantive and minor administrative work were allowed. Seven entries totaling 0.5 attorney hours and 1.0 paralegal hours were found to be entirely administrative (e.g., reviewing a court-filed notice, arranging service of process, providing credit card information for filing fees) and were deducted.
2. Unnecessary work: The Court partially agreed. It deducted 0.2 hours (0.1 attorney, 0.1 paralegal) spent correcting an email oversight — specifically, resending an email that had not copied Midland — as a failure of 'billing judgment.' However, it declined to deduct 1.2 hours Mr. Zelman spent disputing Midland's demand for billing records during fee negotiations, citing Berscheid v. Experian Info. Sols., Inc. (D. Minn. 2023), a prior case against Midland where similar conduct by Midland was criticized and the corresponding attorney time was allowed.
3. Work on other co-defendants: Midland argued that 75% of claimed hours reflected work for defendants other than Midland and that it should pay only 25%. The Court rejected this, noting that Mr. Zelman, as an officer of the court, attested that he had already excluded from the request all time attributable solely to other defendants, and Midland provided no specific evidence to the contrary.
4. Co-counsel communications: The Court declined to deduct 1.8 hours for internal co-counsel communications, finding them adequately documented and reasonable in scope, and noting that local counsel waived all fees, eliminating double-billing concerns.
Hours — Fee Petition
Mr. Zelman claimed 8.4 hours preparing the fee petition and 7.9 hours preparing the reply brief. The Court allowed 8.4 hours for the fee petition as reasonable and unchallenged. It declined to award the 7.9 hours for the reply brief because that request was raised for the first time in the reply itself, violating Local Rule 7.1(c)(3)(B), which prohibits raising new grounds for relief in a reply. The Court noted Singh may file a supplemental motion for those fees.
Further Reduction for Negotiating Conduct
Midland argued Mr. Zelman's conduct during fee negotiations — specifically, conditioning production of his billing records on receiving Midland's records, and his settlement demands — warranted a further fee reduction. The Court rejected this, finding Mr. Zelman acted in good faith: he made prompt settlement offers, followed up repeatedly, and ultimately provided billing records. The Court distinguished cases where courts had penalized attorneys who refused to provide documentation or who engaged in obstructive or harassing behavior.
Costs
Singh sought $590 in costs: a $405 court filing fee, $85 for service on Midland, and a $100 pro hac vice (attorney admission to practice before the court for a specific case) filing fee. Midland did not dispute the $85 service fee but argued it should pay only 25% of the shared filing fees. The Court agreed, holding that each of the four remaining defendants should bear 25% of the shared fees ($101.25 combined for the $405 and $100 fees), yielding $211.25 in total costs.
Ruling
The motion for attorneys' fees and costs was granted in part. The Court ordered Midland to pay Singh a total of $27,886.25: $7,500 (offer of judgment) + $20,175 (attorneys' fees) + $211.25 (costs).
Reviewer note from the AI+
Read the full 16-page opinion on CourtListener, the free public archive maintained by the Free Law Project.