Coley v. DIRECTV, Inc., No. 16-1920 (4th Cir. 2022)
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Coley fraudulently procured satellite television programming from DIRECTV, then sold and distributed that programming to unwitting customers. On a cross-complaint against Coley under the Federal Communications Act, 47 U.S.C. 605(a), the district court found that Coley was liable for 2,393 violations, and awarded DIRECTV a $2,393,000 judgment plus $236,000 in attorneys’ fees. Coley attempted to thwart DIRECTV’s recovery, failing to participate in post-judgment discovery, engaging in extensive dilatory litigation to prevent recovery against his shell companies, failing to comply with court orders, and other fraudulent acts.
The district court amended the damages award to specify that it could be enforced against Coley and the related companies the court found were Coley’s alter egos, with joint and several liability, and later appointed a receiver to aid in the execution of the judgment. The Fourth Circuit affirmed. DIRECTV then sought attorneys’ fees related to the appeal and all post-judgment enforcement proceedings. Coley filed a suggestion of bankruptcy that resulted in an automatic stay of court proceedings. DIRECTV obtained relief from the automatic stay and renewed its motion for $57,295 in fees and $1,403.03 in costs not covered by prior order. The Fourth Circuit granted the motion. Attorneys’ fees and costs incurred while pursuing post-judgment collection and enforcement litigation, including appeals, qualify for compensation under the mandatory fee-shifting provision of the Act.
This opinion or order relates to an opinion or order originally issued on March 28, 2018.
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