Farrar v. Hobby

Joseph Farrar (plaintiff), who ran a school for troubled teens, sued Texas lieutenant governor William Hobby (defendant) and other officials for $17 million after his school was shut down and he was investigated following a student's death, alleging he was deprived of liberty and property without due process. A jury found the officials (except Hobby) conspired against Farrar but that the conspiracy did not proximately cause any actual injury, and the trial court initially awarded nothing; on appeal, the court ordered nominal damages of $1. Based on that $1 award, Farrar sought attorney's fees under 42 U.S.C. § 1988, which the trial court granted but the court of appeals reversed, finding Farrar was not a prevailing party.