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Keywords

lawsuitplaintifflitigationattorneyappealtrialrespondent

lawsuitplaintiffattorneyrespondent

Related Cases

Hensley v. Eckerhart, 461 U.S. 424, 103 S.Ct. 1933, 76 L.Ed.2d 40, 31 Fair Empl.Prac.Cas. (BNA) 1169, 32 Empl. Prac. Dec. P 33,618

Facts

Respondents filed a lawsuit on behalf of individuals involuntarily confined at the Forensic Unit of the Fulton State Hospital, alleging constitutional violations in treatment and conditions. After a trial, the District Court found violations in five of six areas of treatment and awarded attorney fees based on the significant relief obtained. The plaintiffs had previously dismissed some claims and sought fees for hours worked, including those on unsuccessful claims, which the District Court initially included in its award.

Respondents brought this lawsuit on behalf of all persons involuntarily confined at the Forensic Unit of the Fulton State Hospital in Fulton, Missouri.

Issue

Whether a partially prevailing plaintiff may recover attorney's fees for legal services on unsuccessful claims.

The issue in this case is whether a partially prevailing plaintiff may recover an attorney's fee for legal services on unsuccessful claims.

Rule

The extent of a plaintiff's success is a crucial factor in determining the proper amount of an attorney's fee award under 42 U.S.C. § 1988. Where a plaintiff has failed to prevail on a claim unrelated to successful claims, the hours spent on the unsuccessful claim should be excluded.

The extent of a plaintiff's success is a crucial factor in determining the proper amount of an award of attorney's fees under 42 U.S.C. § 1988.

Analysis

The Supreme Court analyzed the District Court's decision, noting that while the plaintiffs achieved significant relief, the court did not adequately consider how the extent of that success related to the attorney fees awarded. The Court emphasized that a reduced fee award is appropriate if the relief obtained is limited compared to the overall litigation. The District Court's findings were commendable, but the failure to properly assess the relationship between success and fees necessitated a remand.

We are unable to affirm the decisions below, however, because the District Court's opinion did not properly consider the relationship between the extent of success and the amount of the fee award.

Conclusion

The Supreme Court vacated the Court of Appeals' decision and remanded the case for further proceedings to determine the proper amount of the attorney's fee award in light of the standards established regarding the extent of success.

We hold that the extent of a plaintiff's success is a crucial factor in determining the proper amount of an award of attorney's fees under 42 U.S.C. § 1988.

Who won?

Respondents prevailed in the case as they were found to have obtained significant relief despite not succeeding on every claim, which justified their status as prevailing parties under § 1988.

Respondents were prevailing parties under § 1988 even though they had not succeeded on every claim.

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