By Michael Rigby
On August 18, 2006, the U.S. District Court for the Southern District of Illinois awarded $7,116.35 in attorney's fees and costs to a state prisoner who prevailed in his civil rights claim against prison officials.
Plaintiff David Williams filed suit against prison personnel under 42 U.S.C. § 1983, claiming their deliberate indifference to his serious medical needs violated his rights under the Eighth Amendment. On July 5, 2006 a jury found in Williams' favor on one count and awarded him $4,500. Following the verdict, the defendants moved for judgment as a matter of law, or in the alternative, a new trial pursuant to Federal Rule of Civil Procedure 50(b). Williams moved for attorney's fees and costs under 42 U.S.C. § 1988.
District Court Judge William D. Stiehl denied the defendants' motion, both for judgment as a matter of law and for a new trial. Regarding the former request, Judge Stiehl held that the defendants were not entitled to qualified immunity -- the only issue not specifically addressed at trial -- because there was enough evidence for a reasonable jury to conclude that the defendants deliberately ignored Williams' complaints of chest pain and numbness in the arm. Likewise, a new trial was not warranted since (a) sufficient evidence existed to provide a reasonable basis for the jury's verdict, and (b) Williams properly alleged a physical injury in conjunction with his mental injury as required by the Prison Litigation Reform Act (PLRA), 42 U.S.C. § 1997e(e).
Judge Stiehl next considered Williams' motion for fees and costs, which he granted in part and denied in part. Williams had sought $6,750.00 in attorney fees, $366.35 in costs that were reflected on his Bill of Costs, and $1,647.13 for "case expenses" not reflected in the Bill of Costs. The judge first noted that as the prevailing party Williams was entitled to reasonable attorney fees and costs.
As for the fees, Judge Stiehl found that $6,750.00, which amounted to 150% of Williams' jury award -- the maximum allowed under the PLRA -- was appropriate. However, Stiehl further found that 25%, or $1,125.00, of the fee award should come from Williams' jury award, leaving the defendants responsible for $5,625.00 of the fee award.
With regard to costs, Judge Stiehl concluded that the $366.35 from the Bill of Costs was appropriate, but that the $1,647.13 in "case expenses" was more properly categorized as attorney fees. As such, Stiehl awarded only the $366.35 in costs because the statutory cap for attorney fees had already been reached. In total, Williams' attorney was awarded $7,116.35 with $1,125.00 of that amount being satisfied from Williams' $4,500 jury award. Williams was represented by Julie A. Bruch of the Northbrook, Illinois, law firm O'Halloran, Kosoff, et al. See: Williams v. Liefer, 2006 U.S. Dist. Lexis 58286.
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Related legal case
Williams v. Liefer
|Cite||2006 U.S. Dist. Lexis 58286|