Summary
The Sixth Circuit held that the district court abused its discretion by vacating an attorney-fee award to Rose Price, who prevailed on claims under the Fair Housing Act and 42 U.S.C. §§ 1981 and 1982. Although Price gave perjured testimony concerning matters unrelated to the defendants’ liability, the court concluded that this misconduct did not constitute special circumstances making a fee award unjust under 42 U.S.C. § 1988. The court reversed and remanded, directing the district court to award reasonable fees for the trial and qualifying post-trial efforts.
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Practice areas
Questions Presented
- Whether the district court abused its discretion by vacating the trial attorney's-fee award under 42 U.S.C. § 1988 because Price had given allegedly perjured testimony that was unrelated to the defendants' liability.
- Whether Price was entitled to reasonable attorney's fees under 42 U.S.C. § 1988 for post-trial efforts that secured access to the apartment and helped her receive the compensatory-damages judgment.
Holdings
- The district court abused its discretion by vacating the attorney's-fee award for the trial on the merits. A prevailing civil-rights plaintiff ordinarily should recover fees under § 1988 unless special circumstances make an award unjust, and Price's perjury did not affect the defendants' admitted liability or the merits of her claims.
- To the extent Price's post-trial efforts enabled her to receive the compensatory-damages award and obtain access to the apartment, she was entitled to reasonable attorney's fees under 42 U.S.C. § 1988.
Key quotations
“Although the language of section 1988 is permissive, the court must exercise its discretion consistent with the congressional purpose underlying this statute.” (690 F.2d at 101)
“Congress intended for prevailing parties to ordinarily recover attorneys fees.” (690 F.2d at 101)
“There are no special circumstances in this case which would render an award of attorney fees unjust.” (690 F.2d at 101)
“The Civil Rights Attorney’s Fees Act should be liberally construed to achieve the public purposes involved in its enactment.” (690 F.2d at 101)
“Accordingly, we hold that the district court abused its discretion in vacating the award of attorney fees for the trial on the merits.” (690 F.2d at 102)
Factual background
The defendants advertised an apartment for rent, told Price, who is Black, that it had already been rented, and allegedly offered the same apartment to a white prospective tenant. The defendants admitted liability for violating the Fair Housing Act and 42 U.S.C. §§ 1981 and 1982 before and during the merits hearing. After the district court awarded damages and attorney's fees and ordered the defendants to provide Price access to the apartment, the defendants refused to comply and later alleged that Price had committed perjury concerning her personal circumstances and prior tenancy.
Procedural history
Price sued under the Fair Housing Act and 42 U.S.C. §§ 1981 and 1982. The district court found the defendants liable, awarded compensatory and punitive damages and attorney's fees, and later ordered the defendants to provide Price access to the apartment. After the defendants alleged that Price had committed perjury, the district court vacated the punitive-damages and trial-attorney-fee awards and denied fees for post-trial motions, while leaving the liability judgment and compensatory damages award intact. The Sixth Circuit reversed and remanded.
Remand instructions
The district court was directed to restore the trial attorney's-fee award and award reasonable attorney's fees for Price's post-trial efforts pursuant to the standards set forth in Northcross.