Kimberly Adams sued the City of Little Rock in the United States District Court for the Eastern District of Arkansas, raising claims of sex discrimination under Title VII of the Civil Rights Act of 1964 and 42 U.S.C. § 1983. The City appealed the district court’s award of attorney’s fees and costs to the United States Court of Appeals for the Eighth Circuit.
Factual Overview
Dr. Kimberly Adams, a former employee of the City of Little Rock, filed a lawsuit alleging sex discrimination in her termination. At trial, Adams sought $390,000 in damages. The jury found that sex was a motivating factor in the City’s decision to fire Adams, but also determined that the City would have fired her regardless. As a result, the jury awarded no damages, and the district court declined to grant injunctive, equitable, or declaratory relief.
Following the trial, Adams filed a motion seeking $49,687.50 in attorney’s fees and $862.00 in costs. The district court awarded no attorney’s fees on her § 1983 claim, finding she was not a prevailing party. However, the court awarded Adams $11,817.75 in attorney’s fees and $258.00 in costs under Title VII, despite her “extremely limited success.” The City appealed this decision.
Legal Analysis
Prevailing Party Status and Attorney’s Fees
The issue in this appeal was whether Adams was entitled to any attorney’s fees and costs given the jury’s verdict and her lack of prevailing party status on the § 1983 claim.
The Eighth Circuit noted that under 42 U.S.C. § 2000e-5(g)(2)(B), the district court had discretion to award attorney’s fees to a Title VII plaintiff who proves a violation under § 2000e-2(m), even if the employer proves it would have taken the same action absent the impermissible motive. However, the court also recognized the principle from Farrar v. Hobby that in civil rights suits for damages where the jury awards no damages, “the only reasonable fee is usually no fee at all.”
Despite this general rule, the Eighth Circuit found that the district court did not abuse its discretion in awarding Adams a reduced amount of attorney’s fees and costs. The court highlighted a unique factor that the district court found dispositive: the City had missed the deadline for filing a summary judgment motion by months, which likely necessitated an unnecessary trial and the expenditure of time and resources by Adams’ counsel.
The Eighth Circuit concluded that the district court properly considered this factor and acted within its substantial discretion in granting Adams a reduced award of attorney’s fees and costs.
The Eighth Circuit affirmed the district court’s order awarding Adams $11,817.75 in attorney’s fees and $258.00 in costs under Title VII.
Schrag on Law 