Klein v. City of Laguna Beach, No. 13-56973 (9th Cir. 2016)
Annotate this CasePlaintiff was awarded nominal damages on three of his four as-applied claims in a 42 U.S.C. 1983 suit to invalidate aspects of Laguna Beach's ordinances prohibiting the use of sound-amplification devices on public sidewalks. Plaintiff then moved for attorneys' fees. The district court concluded that plaintiff was a prevailing party under 42 U.S.C. 1983, but denied attorneys' fees pursuant to Farrar v. Hobby. Farrar held that a prevailing party who seeks a large compensatory award but receives only nominal damages may not be entitled to fees. The court affirmed the district court’s order denying fees under California law. However, under federal law, the court held that because plaintiff's lawsuit achieved its future-oriented goals and plaintiff never attempted to secure compensatory damages under section 1983, the Farrar exception does not apply. Consequently, the district court erred by not considering plaintiff's entitlement to fees under the standard framework. The court vacated and remanded for further proceedings.
Court Description: Civil Rights/Attorneys’ Fees. The panel affirmed the district court’s order denying attorneys’ fees under California law, vacated the denial of attorneys’ fees under federal law, and remanded for further proceedings. In the underlying action brought under 42 U.S.C. § 1983, plaintiff sought to invalidate aspects of Laguna Beach ordinances prohibiting the use of sound-amplification devices on public sidewalks. After winning two appeals in this court, plaintiff was awarded nominal damages on three of his four as-applied claims. The district court concluded that plaintiff was a prevailing party under 42 U.S.C. § 1988, but it denied attorneys’ fees per Farrar v. Hobby, 506 U.S. 103 (1992), which held that a prevailing party who seeks a large compensatory award but receives only nominal damages may not be entitled to fees. The district court also concluded that plaintiff was not entitled to fees under California law because the court had entered judgment for the City on plaintiff’s state claims. The panel affirmed the district court’s order denying fees under California law. Under federal law, the panel held that because plaintiff’s lawsuit achieved its future-oriented goals and plaintiff never attempted to secure compensatory damages under § 1983, the Farrar exception did not apply, KLEIN V. CITY OF LAGUNA BEACH 3 and the district court erred by not considering plaintiff’s entitlement to fees under the standard framework.
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