Cantu-Guerrero v. Lumber Liquidators, Inc., No. 20-2036 (4th Cir. 2022)
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Objectors challenge, for the second time, the district court's award of attorney's fees in association with a class-action settlement. The underlying 2018 settlement resolved two multidistrict litigation (MDL) proceedings related to Lumber Liquidators's sale of defective laminate flooring products. Objectors now contest the district court's application of the Class Action Fairness Act (CAFA) and its use of the lodestar method in calculating the attorney's fees.
The Fourth Circuit affirmed the attorney's fee order, concluding that it is satisfied that the district court correctly applied the relevant CAFA settlement provisions and did not abuse its discretion in approving the attorney's fee award as reasonable. The court agree with the prevailing interpretation of CAFA and thus approved the district court's determination that 28 U.S.C. 1712(b) allowed it to apply the lodestar method in this litigation. Especially in consideration of the district court's intimate familiarity with the litigation that proceeded before it and its unique advantage in determining the fee award is reasonable, the court approved of the district court's lodestar analysis and its assessment of the "success obtained" by class counsel. The court discerned no error in the district court's application of the CAFA "coupon" settlement provision and was satisfied that the attorney's fees order does not reflect an abuse of discretion. Finally, the court upheld the district court's award of fees in the amount of $10.08 million.
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