Farrar v. Hobby

Incident Summary & Facts

Joseph and Dale Farrar ran Artesia Hall, a Texas school for delinquent, disabled, and disturbed teenagers. After a student died in 1973, a grand jury indicted Joseph Farrar for murder, alleging willful failure to provide proper medical treatment and timely hospitalization, and the State obtained a temporary injunction closing the school. Texas Lieutenant Governor William P. Hobby, Jr. issued a press release criticizing the state welfare department’s licensing, urged an investigation, joined the Governor on an inspection of the school, and attended the injunction hearing.

Farrar sued Hobby and five other officials under 42 U.S.C. §§ 1983 and 1985 for conspiracy and malicious prosecution that deprived him of liberty and property without due process, eventually seeking $17 million. After Joseph Farrar died, his estate’s coadministrators took over the case. A jury found that the other defendants conspired but caused no injury, and that Hobby deprived Farrar of a civil right but was not “a proximate cause of any damages.” The Fifth Circuit ordered entry of nominal damages ($1) against Hobby. The district court then awarded about $280,000 in attorney’s fees under 42 U.S.C. § 1988, plus expenses and interest. A divided Fifth Circuit panel reversed, holding the Farrars were not “prevailing parties.” The Supreme Court granted certiorari.

This case did not involve a use-of-force encounter; it concerns attorney’s fees in civil rights litigation.

Core Legal Issue

Whether a civil rights plaintiff who recovers only nominal damages is a “prevailing party” eligible for attorney’s fees under 42 U.S.C. § 1988, and, if so, what fee is reasonable when the plaintiff sought substantial compensatory damages.

The Holding

A plaintiff who wins nominal damages is a “prevailing party” under § 1988. However, when a plaintiff seeking compensatory damages recovers only nominal damages because he failed to prove an essential element of his claim, “the only reasonable fee is usually no fee at all.” The Court therefore affirmed the Fifth Circuit’s reversal of the fee award.

The Court’s Analysis:

• Prevailing-party test: A plaintiff “prevails” when “actual relief on the merits of his claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff” (synthesizing Hewitt, Rhodes, and Garland).
• Nominal damages qualify: A judgment for any amount, even $1, forces the defendant to pay money “he otherwise would not pay.” The prevailing-party inquiry “does not turn on the magnitude of the relief obtained.” A bare declaration that the Constitution was violated, without an enforceable judgment, is not enough.
• Degree of success governs the amount: Under Hensley, “the most critical factor” in setting a reasonable fee “is the degree of success obtained.” A court must compare the damages awarded with the damages sought, and may award low or no fees without a full lodestar calculation.
• Application: The district court awarded $280,000 without weighing $1 recovered against $17 million sought. Fee awards are not meant to “produce windfalls to attorneys.”
• Concurrence (O’Connor, J.): Farrar “asked for a bundle and got a pittance.” The amount recovered, the significance of the legal issue, and any public purpose served all showed a de minimis victory.
• Partial dissent (White, J., joined by Blackmun, Stevens, and Souter, JJ.): Agreed Farrar was a prevailing party but would have remanded for the lower courts to set the fee amount rather than decide that no fee was reasonable.