District court decision to deny awarding attorney's fees to winning plaintiff in FDCPA case involving a minor violation overturned by appeals court, which holds that attorney's fees are mandatory whenever plaintiff wins.

Case Summary:
Zagorski sued Midwest for violating the Fair Debt Collection Practices Act. Midwest, an unlicensed debt collection agency, failed to disclose that it was attempting to collect a debt owed to a hospital and that it would use any information disclosed by Zagorski for that purpose. Midwest admitted to the violations alleged but asserted that they were technical or de minimis violations.

Decision:
District Court Decision Plaintiffs were awarded $100 but their request for attorney's fees was rejected because the violation was held to be de minimis. Plaintiffs appealed. Court of Appeals Decision reversed and remanded. The district court abused its discretion by not awarding attorney's fees. The fact that the violation here was petty is irrelevant; awarding of attorney's fees for any violation of the FDCPA is mandatory.