Farrar v. Hobby

506 U.S. 103 (1992)

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Nature of the Case

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Facts

P owned and operated Artesia Hall, a school for delinquent, disabled, and disturbed teens. After an Artesia Hall student died, a Liberty County grand jury returned a murder indictment charging Joseph (P) with willful failure to administer proper medical treatment and failure to provide timely hospitalization. The State of Texas also obtained a temporary injunction that closed Artesia Hall. Hobby (D), then Lieutenant Governor of Texas, participated in the events leading to the closing of Artesia Hall. After Joseph (P) was indicted, D issued a press release criticizing the Texas Department of Public Welfare and its licensing procedures. He urged the department's director to investigate Artesia Hall and accompanied Governor Dolph Briscoe on an inspection of the school. P sued D, Judge Clarence D. Cain, County Attorney Arthur J. Hartell III, and the director and two employees of the Department of Public Welfare for monetary and injunctive relief under 42 U.S.C. §§ 1983 and 1985. P alleged deprivation of liberty and property without due process by means of conspiracy and malicious prosecution aimed at closing Artesia Hall. Ps eventually requested damages to $17 million. The jury found that all of the defendants except D had conspired against Ps but that this conspiracy was not a proximate cause of any injury suffered by Ps. The jury also found that D had 'committed an act or acts under color of state law that deprived Ps of a civil right,' but it found that D's conduct was not 'a proximate cause of any damages' suffered. The District Court ordered that Ps take nothing, that the action be dismissed on the merits, and that the parties bear their own costs. The Fifth Circuit reversed in part and remanded for entry of judgment against D for nominal damages. Ps then sought attorney's fees under 42 U.S.C. §1988. The District Court entered an order awarding Ps $280,000 in fees, $27,932 in expenses, and $9,730 in prejudgment interest against D. A Fifth Circuit panel reversed the fee award. It determined that Ps were not prevailing parties and were therefore ineligible for fees under §1988. The Supreme Court granted certiorari.