Supreme Court of the United States

Farrar, Coadministrators of Estate of Farrar, Deceased v. Hobby

December 14, 1992506 U.S. 103

Summary

Justice Thomas, joined by Chief Justice Rehnquist and Justices O'Connor, Scalia, and Kennedy, held that a civil rights plaintiff awarded nominal damages is a prevailing party eligible for attorney's fees under 42 U.S.C. § 1988, but affirmed the denial of fees because Farrar's minimal success justified no fee. Justice O'Connor concurred separately, explaining that the extent of relief, significance of the legal issue, and public purpose served demonstrated a merely de minimis victory. Justice White, joined by Justices Blackmun, Stevens, and Souter, agreed that Farrar was a prevailing party but dissented from the disposition; he would have vacated and remanded for reconsideration of the fee amount rather than deciding an issue not presented in the certiorari petition or briefed by petitioners.

Holding

  • Prevailing-party status following an award of nominal damages.. A plaintiff who wins nominal damages is a prevailing party under § 1988, regardless of the magnitude of the relief obtained.
  • Reasonableness of attorney's fees for Farrar's nominal damages victory.. Farrar was entitled to no attorney's fees despite prevailing-party status. A plaintiff seeking compensatory damages who recovers only nominal damages because of a failure to prove an essential element of monetary relief usually should receive no fees.

Docket 91-990

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