Perez-Sosa v. Garland, No. 20-2083 (1st Cir. 2022)
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The First Circuit affirmed all but two of the district court's rulings in this dispute over the amount of attorneys' fees due to Plaintiff, the prevailing party in the underlying employment discrimination dispute, and vacated the attorneys' fees award, holding that the district court erred in part.
Plaintiff, the former head of the appellate practice of the United States Attorney's Office for the District of Puerto Rico, alleging discrimination and retaliation under Title VII. The parties negotiated a settlement, under which Plaintiff received a lump-sum payment of $450,000 plus reasonable attorneys' fees. The district court awarded Plaintiff a total of $170,332 in attorneys' fees. The First Circuit affirmed all but two of the district court's rulings, which the court reversed, and vacated the fee award, holding (1) the district court erred in concluding that time expended in settlement negotiations and time expended in performing work that implicated other cases, distinct but related, must be categorically excluded from the fee award; and (2) Plaintiff's five remaining challenges were without merit.
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