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Hyundai v. Alley
State: Maryland
Court: Court of Appeals
Docket No: 1495/07
Case Date: 12/02/2008
Preview:REPORTED IN THE COURT OF SPECIAL APPEALS OF MARYLAND No. 1495 September Term, 2007

HYUNDAI MOTOR AMERICA v. ANGELA R. ALLEY

Hollander, Zarnoch, Wright, JJ.

Opinion by Zarnoch, J.

Filed: December 2, 2008

Appellant, Hyundai Motor America, is appealing a decision by the Circuit Court for Cecil County awarding attorney's fees to appellee, Angela Alley, under the fee shifting provisions of the Maryland Automotive Warranty Enforcement Act, the Maryland Consumer Protection Act, and the federal Magnuson-Moss Warranty Act. The fees were awarded after the parties negotiated a settlement of the case, and prior to any adjudication of the merits of appellee's claims. Appellant presents the following questions: 1. Did the circuit court err in granting appellee's petition for attorney's fees and costs based on a finding that appellee was a prevailing party under the fee shifting statutes at issue? Did appellee satisfy her burden of presenting legally sufficient evidence as to the reasonableness of the fees claimed in order to support any fee award by the circuit court? Did the circuit court properly apply the lodestar analysis in determining the amount of attorney's fees to award?

2.

3.

For the following reasons, we affirm in part and vacate and remand in part. FACTS AND LEGAL PROCEEDINGS On June 19, 2006, Angela R. Alley ("Alley"), appellee, filed suit against Hyundai Motor America ("Hyundai"), appellant, in the Circuit Court for Cecil County, relating to the purchase of a new vehicle that was defective. Appellee alleged various claims arising under the Maryland Automotive Warranty Enforcement Act ("AWEA"), Md. Code Ann. (1975, 2005 Repl. Vol., 2007 Supp.),
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