Shadis v. Beal
United States Court of Appeals for the Third Circuit
685 F.2d 824 (1982)
Community Legal Services (CLS), a federally funded nonprofit providing legal services to the poor, operated under contracts with Pennsylvania (defendant) barring CLS from recovering attorney's fees in any lawsuit against the state; CLS nonetheless won a federal civil rights class action on behalf of Medicaid recipients wrongfully denied benefits, and the prevailing class sought attorney's fees under the federal Civil Rights Attorney's Fees Award Act. Pennsylvania objected based on the no-fee contract provisions, but the trial court found those provisions void as contrary to the public policy behind the Act's fee-shifting scheme and awarded CLS its fees; Pennsylvania appealed.
Whether contract provisions that subvert public policy interests protected by federal law are unenforceable.