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Farrar v. Hobby, 506 U.S. 103 (1992)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Farrar v. Hobby, 506 U.S. 103 (1992)
Farrar v. Hobby No. 91-990 Argued Oct. 7, 1992 Decided Dec. 14, 1992 506 U.S. 103
CERTIORARI TO THE UNITED STATES OF APPEALS
FOR THE FIFTH CIRCUIT
Syllabus
Petitioners, coadministrators of decedent Farrar’s estate, sought $17 million in compensatory damages, pursuant to 42 U.S.C. §§ 1983 and 1985, from respondent Hobby and other Texas public officials for the alleged illegal closure of the school that Farrar and his son operated. However, the Federal District Court awarded them only nominal damages, and, subsequently, awarded them $280,000 in attorney’s fees under 42 U.S.C. § 1988. The Court of Appeals reversed the fee award on the ground that petitioners were not prevailing parties eligible for fees under § 1988.
Held:
1. A plaintiff who wins nominal damages is a prevailing party under § 1988. A plaintiff "prevails" when actual relief on the merits of his claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff. Hewitt v. Helms, 482 U.S. 755; Rhodes v. Stewart, 488 U.S. 1; Texas State Teachers Assn. v. Garland Independent School Dist., 489 U.S. 782. Here, petitioners were entitled to nominal damages under Carey v. Piphus, 435 U.S. 247, 266, because they were able to establish Hobby’s liability for denial of procedural due process, but could not prove the actual injury necessary for a compensatory damages award. Judgment for nominal damages entitled petitioners to demand payment and modified Hobby’s behavior for petitioners’ benefit by forcing him to pay an amount of money he otherwise would not have paid. The prevailing party inquiry does not turn on the magnitude of the relief obtained, and whether a nominal damages award is a "technical," "insignificant" victory does not affect the plaintiff’s prevailing party status. Cf. Garland, supra, 489 U.S. at 792. Pp. 109-114.
2. Petitioners are not entitled to a fee award. While the "technical" nature of a nominal damages award does not affect the prevailing party inquiry, it does bear on the propriety of fees awarded under § 1988. The most critical factor in determining a fee award’s reasonableness is the degree of success obtained, since a fee based on the hours expended on the litigation as a whole may be excessive if a plaintiff achieves only partial or limited success. Hensley v. Eckerhart, 461 U.S. 424, 436. When a plaintiff recovers only nominal damages because of his failure to prove an essential element of his claim for monetary relief, the only reasonable fee is usually no fee at all. In light of "the relationship between" the extent of petitioners’ success on the merits and the award’s amount, id. at 438, the reasonable fee was not the District Court’s $280,000 award, but no fee at all. Pp. 114-116.
941 F.2d 1311 (CA5 1991), affirmed.
THOMAS, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and O’CONNOR, SCALIA, and KENNEDY, JJ., joined. O’CONNOR, J., filed a concurring opinion, post, p. 116. WHITE, J., filed an opinion concurring in part and dissenting in part, in which BLACKMUN, STEVENS, and SOUTER, JJ., joined, post, p. 122.
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Chicago: U.S. Supreme Court, "Syllabus," Farrar v. Hobby, 506 U.S. 103 (1992) in 506 U.S. 103 506 U.S. 104–506 U.S. 105. Original Sources, accessed November 25, 2024, http://originalsources.com/Document.aspx?DocID=SYA34A6SU8L9FL3.
MLA: U.S. Supreme Court. "Syllabus." Farrar v. Hobby, 506 U.S. 103 (1992), in 506 U.S. 103, pp. 506 U.S. 104–506 U.S. 105. Original Sources. 25 Nov. 2024. http://originalsources.com/Document.aspx?DocID=SYA34A6SU8L9FL3.
Harvard: U.S. Supreme Court, 'Syllabus' in Farrar v. Hobby, 506 U.S. 103 (1992). cited in 1992, 506 U.S. 103, pp.506 U.S. 104–506 U.S. 105. Original Sources, retrieved 25 November 2024, from http://originalsources.com/Document.aspx?DocID=SYA34A6SU8L9FL3.
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