League of Women Voters of Missouri v. Ashcroft, No. 20-2440 (8th Cir. 2021)
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In 2018, plaintiffs filed suit against Missouri under Section 5 of the National Voter Registration Act of 1993. Plaintiffs ultimately obtained a preliminary injunction requiring Missouri to send voter registration forms to thousands of Missouri citizens and to make certain changes to its voter registration procedures in time for the 2018 midterm elections. In 2019, the parties entered into a settlement agreement that resolved all remaining issues except for attorney's fees. The district court noted that Missouri did not dispute plaintiffs' status as the prevailing party, and therefore granted plaintiffs' motion for attorney's fees a few months later and awarded plaintiffs $1,143,627.96 in fees and $27,484.15 in litigation expenses.
The Eighth Circuit affirmed, concluding that the district court did not abuse its discretion in finding that plaintiffs reasonably expended 3,251.38 hours on this matter. The court also concluded that the district court sufficiently considered the Johnson factors in determining the reasonableness of the lodestar amount and did not abuse its discretion.
Court Description: [Kelly, Author, with Grasz and Kobes, Circuit Judges] Civil case - Attorneys' Fees. Defendants did not dispute that plaintiff was the prevailing party in this suit to obtain injunctive relief under Section 5 of the Registration Act of 1993, and the district court did not abuse its discretion in granting plaintiffs $1.14 million in fees and $27, 484 in costs.
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