Civil Procedure – Attorney’s fee in consumer auto case requires ‘Smith’ analysis 

The trial court abused its discretion by summarily awarding plaintiff a $1,000 attorney’s fee after she settled her claims against a used car dealer. The fee request should have been analyzed with regard to the Magnuson-Moss Warranty Act and the Michigan Consumer Protection Act’s fee-shifting provisions and Smith v. Khouri, 481 Mich. 519 (2008).

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