By: WISCONSIN LAW JOURNAL STAFF//June 20, 2014//
U.S. Court of Appeals for the 7th Circuit
Civil
Civil Rights — attorney fees
Where the plaintiff recovered only $2,000 in damages in a civil rights action, it was not an abuse of discretion for the district court to award only $108,000 of the $400,000 attorney fee request.
“The judge did not make the mistake of limiting the fee to some multiple of the judgment, which would have been reversible error. See id. at 545. Instead, after finding that the attorneys’ expenditure of time could not be explained by the complexity of the facts or the relevant legal doctrine, or by the vindication of an important public interest, see City of Riverside v. Rivera, 477 U.S. 561, 574, 579 (1986) (plurality opinion), the judge treated the disproportionate fees as an indicator that Montanez and his attorneys unrealistically believed these claims were worth far more than they recovered. The 50% reduction was not an abuse of discretion, and the final fee award of $108,350.87 was quite ‘generous in relation to [Montanez’s] recovery.’ Richardson, 740 F.3d at 1103.”
Affirmed.
Appeal from the United States District Court for the Northern District of Illinois, Finnegan, Mag. J., Sykes, J.