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9th Circuit Remands Case to District Court to Explain Its Order Reducing Prevailing Party’s Fee Request
In February, 2013, the Ninth Circuit vacated a district court’s award of costs and attorney’s fees to a prevailing § 1983 litigant because the district court failed to explain how it arrived at its determination that the amount requested was excessive.
Joseph and Darla Padgett filed a complaint asserting various state and federal causes of action stemming from a dispute over enforcement of an ordinance regulating the height of fences in the City of Monte Sereno, California. When the dust settled, Joseph Padgett had prevailed on one claim—a § 1983 First Amendment retaliation claim—against one defendant. The jury awarded him just $1.00 in nominal damages, but $200,000 in punitive damages.
Responding to Joseph Padgett’s request for attorney’s fees, the district court noted that this case was “a textbook example of disproportionate litigation in retaliation to the actual damages.” It then reduced his request for attorney’s fees from $3.2 million to $500,000 and his request for costs from $900,000 to $100,000.
On appeal, the Ninth Circuit vacated the award of costs and attorney’s fees because the district court failed to “show [its] work” as required by circuit precedent, making it impossible for the panel to determine whether or not the district court had abused its discretion. See: Padgett v. Loventhal, 706 F. 3d 1205 (9th Cir. 2013).
Joseph and Darla Padgett filed a complaint asserting various state and federal causes of action stemming from a dispute over enforcement of an ordinance regulating the height of fences in the City of Monte Sereno, California. When the dust settled, Joseph Padgett had prevailed on one claim—a § 1983 First Amendment retaliation claim—against one defendant. The jury awarded him just $1.00 in nominal damages, but $200,000 in punitive damages.
Responding to Joseph Padgett’s request for attorney’s fees, the district court noted that this case was “a textbook example of disproportionate litigation in retaliation to the actual damages.” It then reduced his request for attorney’s fees from $3.2 million to $500,000 and his request for costs from $900,000 to $100,000.
On appeal, the Ninth Circuit vacated the award of costs and attorney’s fees because the district court failed to “show [its] work” as required by circuit precedent, making it impossible for the panel to determine whether or not the district court had abused its discretion. See: Padgett v. Loventhal, 706 F. 3d 1205 (9th Cir. 2013).
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Related legal case
Padgett v. Loventhal
| Year | 2013 |
|---|---|
| Cite | 706 F.3d 1205 (9th Cir. 2013) |
| Level | Court of Appeals |
| Attorney Fees | 600,000.00 |
| Damages | 200,001.00 |