Farrar v. Hobby

Background

A father who ran a private school sued state officials after a student’s death, claiming they shut the school down and violated his and the school’s rights. He sought $17 million in damages and, after trial, the jury found that one official violated a civil right but awarded only one dollar in nominal damages. The plaintiffs then sought attorney’s fees under the federal civil‑rights fee statute.

Reasoning

The Court addressed whether a plaintiff who gets only nominal damages is a “prevailing party” eligible for fees under 42 U.S.C. §1988. Relying on earlier decisions, the Court said a plaintiff who obtains an enforceable judgment that alters the legal relationship with a defendant can be a prevailing party — and that a nominal damages judgment can qualify. But the Court explained that the small size of the recovery matters when deciding reasonable fees, and that a plaintiff who sought large compensatory awards but recovered only nominal damages often should receive no fees.

Real world impact

The ruling means people who win nominal awards can be eligible to claim attorney’s fees, but lower courts may lawfully deny or sharply reduce fees when the victory is merely symbolic. In this specific case the Supreme Court affirmed the denial of fees because the one‑dollar result was a de minimis victory compared to the $17 million sought.

Dissents or concurrances

Justice O’Connor agreed no fees were appropriate here; Justice White (joined by three others) agreed on prevailing‑party status but would remand to reconsider the fee amount.