Facts of the Case

In 1975, eight Chicano individuals were attending a party that was broken up by the Riverside police using tear gas and physical force without a warrant. Subsequently, the eight individuals filed suit in Federal District Court against the city and various police officers under several federal Civil Rights Acts, alleging violations of their First, Fourth, and Fourteenth Amendment rights. The jury found in the individuals' favor and awarded $33,350 in compensatory and punitive damages. The individuals also sought attorney's fees under the Civil Rights Attorney's Fees Awards Act of 1976 in the amount of $245,456.25, based on 1,946.75 hours expended by their two attorneys at $125 per hour and 84.5 hours expended by law clerks at $25 per hour. Finding both the hours and rates reasonable, the District Court awarded the requested amount, and the Court of Appeals affirmed. The appellate court found that the fee award was not excessive merely because it exceeded the amount of damages awarded by the jury.

Question

Is an award of attorney's fees under the Civil Rights Attorney's Fees Awards Act of 1976 "unreasonable" within the meaning of the statute if it exceeds the amount of damages recovered by the plaintiff in the underlying civil rights action?

Conclusion

No. In an opinion delivered by Justice William J. Brennan, Jr., the Court held, 5-4, that there was no requirement under Civil Rights Attorney's Fees Awards Act of 1976 that attorneys' fees be proportionate to the amount of damages a civil rights plaintiff might recover. Justice Brennan, joined by Justices Thurgood Marshall, Harry A. Blackmun, and John Paul Stevens, reasoned that such plaintiffs seek to vindicate important constitutional rights that cannot be valued solely in monetary terms, and a proportionality requirement would seriously undermine Congress's purpose under the Act to insure the availability of counsel in civil rights cases. Concurring, Justice Lewis F. Powell, Jr., reasoned that neither the prior decisions of the Supreme Court nor the legislative history of the Act supported such a requirement.