Pulliam v. HNL Automotive, Inc.

Summary

The court held that the Holder Rule's cap on recovery does not limit attorney's fees awarded against a contract holder under a state prevailing-party statute. The phrase "recovery hereunder" limits only recovery based on claims or defenses extended from the seller to the holder through the Holder Rule, not fees independently authorized by state law. The court affirmed the Court of Appeal's judgment and declined to decide whether the agency's interpretation independently warranted deference because that interpretation was consistent with the court's reading.