Maine v. Thiboutot
United States Supreme Court
448 U.S. 1 (1980)
Lionel and Joline Thiboutot (plaintiffs) sued Maine and its Commissioner of Human Services (defendants) after the state reduced welfare benefits calculated for Lionel's three children from a prior marriage, alleging both a violation of the federal Social Security Act and a civil rights violation under 42 U.S.C. § 1983, and separately seeking attorney's fees under 42 U.S.C. § 1988. The trial court awarded retroactive benefits and enjoined the challenged rule but denied attorney's fees; on the Thiboutots' appeal of just the fee ruling, the Maine Supreme Judicial Court found no fee entitlement under state law but held fees were available under § 1988, and the U.S. Supreme Court granted certiorari.
Whether the federal civil rights statute, 42 U.S.C. § 1983, provides a remedy for violations of federal statutory rights as well as constitutional rights.