California: District Court Awards Attorneys' Fees in Excess of $700,000 Despite Jury Award of Only Nominal Damages to Plaintiff in § 1983 Wrongful Death Suit
In December 2010, the Honorable Christina A. Snyder, U.S. District Judge for the Central District of California, awarded attorneys' fees in the amount of $719,417.00 and costs in the amount of $13,541.92 to the plaintiffs in a wrongful death § 1983 lawsuit where the jury found City of Los Angeles detectives Martin Pinner and Juan Rodriguez (the defendants) civilly liable for the death of Martha Puebla, but then declined to award her parents any compensatory or punitive damages.
In May 2003, Martha Puebla was killed after detectives Pinner and Rodriguez allegedly disclosed (falsely) to Vineland Boyz gang member Jose Ledesma that Martha had identified him in a lineup as the perpetrator of a homicide. Five years later, Martha's parents filed suit in federal court against the City of Los Angeles, Chief William Bratton, and detectives Pinner and Rodriguez, alleging (among other claims) wrongful death and negligence.
In April 2010, following a trial, the jury found, by a preponderance of evidence: the detectives had violated the Due Process rights of Martha and/or her parents; that they had acted negligently; that their negligence was a substantial contributing factor in Martha's death; and that they had acted with reckless disregard for the rights of Martha and/or her parents.
But the jury also found that Martha and/or her parents had acted negligently and that that negligence likewise was a substantial factor in causing Martha's death.
The jury apportioned 20% of the responsibility for Martha's death to the detectives (with the remaining 80% to Martha herself and/or her parents) and then declined to award her parents economic damages, non-economic damages, or punitive damages.
The Court awarded Martha's parents $1 in nominal damages, which paved the way for them, as the "prevailing party," to move for attorneys' fees and costs pursuant to 42 U.S.C. § 1988. Relying on Mahach-Watkins v. Depee, 593 F.3d 1054, 1060 (9th Cir. 2010), the Court concluded that, insofar as the case resulted in a wrongful death, it "'involves significant legal issues, serves a public purpose, and affirms important rights, regardless of the amount of damages recovered.'" See: Rauda v. City of Los Angeles, Case No. CV 08-3128-CAS (PJW), (U.S.D.C., C.D. Cal., 2010).
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Related legal case
Rauda v. City of Los Angeles
|Cite||Case No. CV 08-3128-CAS (PJW), (U.S.D.C., C.D. Cal., 2010)|