Akins

The trial court awarded respondents Ariana Akins and her daughter $85,490 in attorney fees to be paid by appellants Enterprise Rent-A-Car Company of San Francisco and Matthew Lehr. Enterprise and Lehr appeal, contending that the trial court erred by not requiring Akins to present a fee claim limited to attorney fees incurred on the successful Rosenthal Fair Debt Collection Practices Act (FDCPA or the Act) cause of action. (See Civ. Code, §§ 1788-1788.32.) In her brief, Akins also seeks an award of attorney fees on appeal. We affirm the attorney fees order and grant the request for fees on appeal.

I. Facts

On June 3, 1996, respondent Ariana Akins—a low-income single mother—put $397 in cash and some personal property in a vehicle that a third party had rented from appellant Enterprise Rent-a-Car Company of San Francisco. Akins saw Enterprise employee and appellant Matthew Lehr attempting to repossess the vehicle and asked him for her possessions. He refused; Akins attempted to retrieve her belongings. Lehr drove off with Akins hanging from the car, injuring her. Akins’s daughter witnessed these events. Lehr knew that Akins was not the renter of the vehicle, but suspected…