Evans v. Jeff D.
United States Supreme Court
475 U.S. 717 (1986)
Jeff D. (plaintiff), representing a class of institutionalized children with mental and emotional disabilities, sued Idaho's governor, Evans (defendant), seeking improved treatment conditions. The class's attorney had no fee agreement with the class. Before trial, Idaho offered a settlement granting nearly all the requested injunctive relief, but conditioned on the class waiving attorney's fees, with the waiver itself subject to the district court's approval. The district court approved the settlement including the fee waiver and denied the class's later motion for fees. The court of appeals invalidated the waiver and remanded for a fee award. The Supreme Court granted certiorari.
Whether a district court has discretion to approve a civil-rights class-action settlement granting prospective injunctive relief on the condition that the defendants pay none of the prevailing party's attorney's fees.