CITY OF RIVERSIDE Et Al. v. RIVERA Et Al.
Headline: Court pauses enforcement of a huge attorney-fee award against a city and police officers, allowing review of whether fees can be cut because they far exceed the small money judgment.
Holding: The Justice granted a stay of the Ninth Circuit’s mandate requiring the city and officers to pay $245,456.25 in attorney’s fees while the Court considers whether such fees may be reduced as disproportionate to the $33,350 judgment.
- May reduce large attorney-fee awards when damages are small.
- Gives cities and officers temporary relief from paying contested fees.
- Could change how courts factor damages into fee awards.
Summary
Background
Respondents sued the city of Riverside and numerous police officers after officers broke up a private party, arrested several guests, and later had charges dismissed for lack of probable cause. After a nine-day trial a jury awarded respondents $33,350 for several constitutional violations and common-law claims. The District Court then awarded $245,456.25 in attorney’s fees under 42 U.S.C. §1988; the Ninth Circuit affirmed, and the fee award survived a remand under this Court’s earlier decision in Hensley v. Eckerhart.
Reasoning
The core question is whether a court deciding a “reasonable” fee under §1988 may take into account how small the money judgment was. Justice Rehnquist notes the statute’s legislative history and prior guidance that the amount recovered can be a relevant factor; other federal appeals courts disagree whether disproportionality may ever justify reducing fees. Because the fee here is more than seven times the monetary award, the Justice concluded that the issue is important, that the applicants have a substantial chance of success on the merits, and that the Ninth Circuit’s mandate should be stayed while the higher court considers the question.
Real world impact
If the Court ultimately rules that courts may reduce fees based on a small money recovery, many large fee awards in civil-rights suits could be narrowed, affecting plaintiffs’ lawyers, individual plaintiffs, and local governments. The stay is temporary; the final rule could change how judges calculate fees and how lawyers bill and litigate civil-rights cases. The question of bond interest was left for the District Court to address.
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