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Keywords

plaintiffdamageslitigationattorneyappealcivil rights
plaintiffdefendantdamagesattorneylawyerstatuteappealcivil rightsrespondent

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Blanchard v. Bergeron, 489 U.S. 87, 109 S.Ct. 939, 103 L.Ed.2d 67, 49 Fair Empl.Prac.Cas. (BNA) 1, 49 Empl. Prac. Dec. P 38,722, 57 USLW 4191

Facts

Arthur J. Blanchard sued Sheriff's Deputy James Bergeron for civil rights violations under 42 U.S.C. § 1983, claiming he was beaten while at a bar. A jury awarded him $10,000 in damages, and he sought over $40,000 in attorney's fees under 42 U.S.C. § 1988. The District Court awarded $7,500 in fees, but the Court of Appeals reduced this to $4,000, citing Blanchard's 40% contingent-fee agreement with his attorney as a cap on the fee award.

After a jury awarded petitioner $10,000 in damages on his claim that respondent sheriff's deputy had beaten him and thereby deprived him of his civil rights under 42 U.S.C. § 1983, the Federal District Court awarded him $7,500 in attorney's fees under 42 U.S.C. § 1988.

Issue

Whether an attorney's fee allowed under 42 U.S.C. § 1988 is limited to the amount provided in a contingent-fee arrangement entered into by a plaintiff and his counsel.

The issue before us is whether an attorney's fee allowed under 42 U.S.C. § 1988 is limited to the amount provided in a contingent-fee arrangement entered into by a plaintiff and his counsel.

Rule

An attorney's fee allowed under § 1988 is not limited to the amount provided in the plaintiff's contingent-fee arrangement with his counsel, and the court must determine a reasonable fee based on the hours worked and prevailing rates.

An attorney's fee allowed under § 1988 is not limited to the amount provided in the plaintiff's contingent-fee arrangement with his counsel.

Analysis

The Supreme Court found that the Court of Appeals erred in limiting the fee award based on the contingent-fee agreement. The Court emphasized that the Civil Rights Attorney's Fees Award Act requires a reasonable fee to be determined by multiplying the number of hours reasonably expended on the litigation by a reasonable hourly rate, which should not be automatically capped by any private fee arrangement. The Court noted that the legislative history supports the idea that fee arrangements are just one of many factors to consider in determining reasonable fees.

To hold otherwise would be inconsistent with the statute, which broadly requires all defendants to pay a reasonable fee to all prevailing plaintiffs if ordered to do so by the court acting in its sound judgment and in light of all the circumstances of the case.

Conclusion

The Supreme Court reversed the Court of Appeals' decision and remanded the case for further proceedings to determine the total fee award without the limitation of the contingent-fee agreement.

Accordingly, the judgment of the Court of Appeals is reversed, and the case is remanded for further proceedings consistent with this opinion.

Who won?

Arthur J. Blanchard prevailed in the case because the Supreme Court ruled that the attorney's fees should not be limited by the contingent-fee agreement, allowing for a potentially higher fee based on the reasonable value of the legal services provided.

The Court of Appeals reduced the fee award to $4,000, ruling that petitioner's 40% contingent-fee arrangement with his lawyer served as a cap on the amount of fees that could be awarded.

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