City of Riverside v. Rivera
United States Supreme Court
477 U.S. 561 (1986)
Eight Chicano plaintiffs sued Riverside (defendant) and thirty officers after officers used unnecessary force breaking up a party; a jury awarded 37 individual verdicts totaling $33,350 in damages, and the plaintiffs sought $245,456.25 in attorney's fees under § 1988, which the district court awarded based on hours reasonably spent multiplied by prevailing market rates. After the Supreme Court initially vacated and remanded for the district court to re-examine the award, the district court reaffirmed the same fee amount, and the court of appeals upheld it again, rejecting the argument that the fee was excessive relative to damages.
Whether, in a civil rights action, an award of attorney's fees under 42 U.S.C. § 1988 is necessarily unreasonable where it exceeds the amount of damages recovered in the case.