Maher v. Gagne

Summary

The Supreme Court held that a plaintiff who obtains substantial relief through a consent decree may qualify as a prevailing party entitled to attorney's fees under 42 U.S.C. § 1988, even without an adjudication that constitutional rights were violated. The Court also held that Congress acted within its Fourteenth Amendment enforcement power in authorizing a fee award where a statutory claim was favorably resolved and a substantial constitutional claim remained pending. The judgment affirming the award of fees against Connecticut officials was affirmed.

Holdings

1. Section 1988 applies to all types of § 1983 actions, including actions based solely on violations of the Social Security Act, and a plaintiff may be a prevailing party when relief is obtained through a consent decree without a judicial determination that constitutional rights were violated.
2. The Eleventh Amendment does not bar an award of attorney's fees under § 1988 where the plaintiff prevails on a statutory claim pendent to substantial constitutional claims that remain in the case until a favorable settlement, even though no constitutional violation is adjudicated.

Questions Presented

1. Whether 42 U.S.C. § 1988 authorizes an award of attorney's fees in a § 1983 action based on a Social Security Act claim, including when the plaintiff obtains relief through a consent decree rather than an adjudication on the merits.
2. Whether the Eleventh Amendment bars an award of attorney's fees against state officials when the plaintiff prevails on a statutory claim and the substantial constitutional claims are settled without adjudication.

Disposition

affirmed