City Of Riverside v. Rivera

477 U.S. 561 (1986)

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Nature Of The Case

This section contains the nature of the case and procedural background.

Facts

Ps attended a party at a home of a friend and a large number of unidentified police officers, acting without a warrant broke up the party using tear gas and as found by the District Court, unnecessary physical force. Many of the guests and Ps were arrested. The District Court later found that the party was not creating any disturbance in the community at the time of the break-in. Criminal charges against Ps were dismissed for lack of probable cause. Ps sued the City of Riverside (D) and 31 individual police officers under 42 U.S.C. 1981,1983, 1985(3) and 1986 for violations of their First, Fourth, and Fourteenth Amendment rights. The complaint alleged state law claims and sought damages and declaratory and injunctive relief. Ps got the verdicts they were looking for on a large number of counts against a large number of individuals. Ps were awarded $33,350 in compensatory and punitive damages: $13,300 for their state claims and $20,050 for their federal claims. Ps then sought attorney fees under 1988. They wanted compensation for 1,946.75 hours expended by their two attorneys at a rate of $125 per hour and money for paralegal fees for a total of $245,456.25. The District Court found the hours and the rates reasonable and awarded the attorney’s fees to Ps. Ds appealed. The Ninth Circuit affirmed. The Supreme Court granted certiorari and vacated the Court of Appeals' judgment, and remanded the case for reconsideration in light of Hensley v. Eckerhart. The District Court made extensive findings of fact and conclusions of law and again concluded that Ps were entitled to an award of $245,456.25 in attorney's fees. Ds alleged that the fee was not reasonable, as it was disproportionate to the amount of damages recovered by Ps. The Court of Appeals rejected the argument that the fee award was excessive because it exceeded the amount of damages awarded by the jury. The Supreme Court granted certiorari.

Issues

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Holding & Decision

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Legal Analysis

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