Maher v. Gagne

Background

A state official who runs Connecticut’s Aid to Families with Dependent Children program was sued by a working AFDC recipient. She claimed state rules wrongly limited deductions for work-related expenses, cutting her benefits, and alleged violations of the Social Security Act and the Fourteenth Amendment. The state amended its rules and the parties entered a consent decree that increased standard allowances and let recipients prove actual expenses. The district court later awarded her attorney’s fees and the courts below upheld that award.

Reasoning

The Court considered whether a plaintiff who wins by consent decree can recover fees and whether the Eleventh Amendment bars fees against a State when there is no judicial finding of a constitutional violation. The Court held that the fee law applies to actions like this, that a consent-decree beneficiary can be a “prevailing party,” and that fees may be awarded when substantial constitutional claims remained in the case. It relied on prior decisions saying Congress can authorize fee awards under its Fourteenth Amendment enforcement power.

Real world impact

The decision means people who secure changes to state benefit rules through settlement can also get lawyer fees when important constitutional questions are part of the case. State officials may be required to pay fees even if a court never ruled the Constitution was violated. The opinion did not decide every possible situation, and the award here turned on the presence of substantial constitutional claims.

Dissents or concurrances

A concurrence by Justice Powell, joined by the Chief Justice and Justice Rehnquist, agreed the fee award was proper here but declined to rely on broader reasoning about fee awards in cases without any constitutional claim.