Ela v. Destefano, No. 16-11548 (11th Cir. 2017)Annotate this Case
Plaintiff filed suit against a sheriff's deputy for improperly accessing and viewing her private information on Florida driver's license databases. The district court granted plaintiff's motion for judgment as a matter of law and held the deputy liable under the Driver's Privacy Protection Act (DPPA) and 42 U.S.C. 1983. The Eleventh Circuit affirmed the liquidated damages award where the district court did not abuse its discretion in shaping a damages award appropriate for the facts of this case. The court held, however, that the district court failed to start with the lodestar and gave too much weight to the eighth Johnson factor (the amount involved and the results obtained). Accordingly, the court reversed and remanded for the district court to recalculate an appropriate amount of attorneys' fees.