## Facts

- In 1975, eight Chicano individuals attended a party in Riverside, California.
- Riverside police officers, acting without a warrant, broke up the gathering using tear gas and physical force; several guests, including four plaintiffs, were arrested.
- Criminal charges arising from the incident were later dismissed.
- The arrestees and other attendees sued the City of Riverside, the police chief, and numerous officers under federal civil-rights statutes, alleging First, Fourth, and Fourteenth Amendment violations, plus related state-law claims.
- After narrowing of claims and parties, a jury returned 37 verdicts for plaintiffs against the city and five officers, including findings of 11 violations of 42 U.S.C. § 1983, 4 instances of false arrest and imprisonment, and 22 instances of negligence.
- The jury awarded $33,350 in compensatory and punitive damages.
- Plaintiffs sought $245,456.25 in attorneys’ fees under 42 U.S.C. § 1988 based on 1,946.75 attorney hours at $125/hour and 84.5 law-clerk hours at $25/hour; the district court found the hours and rates reasonable and awarded the full amount.
- The Ninth Circuit affirmed; after a Supreme Court vacatur and remand for reconsideration under Hensley v. Eckerhart, the district court again awarded the full fee and the Ninth Circuit again affirmed.

## Issues

1. Whether an attorneys’ fee award under 42 U.S.C. § 1988 is unreasonable solely because it exceeds the plaintiff’s damages recovery in the underlying civil-rights action.
2. How the “results obtained” factor under Hensley v. Eckerhart bears on reasonableness when plaintiffs prevail on significant claims but recover modest damages.

## Decision

- The Supreme Court affirmed the judgment upholding the fee award.
- A plurality concluded § 1988 does not impose a proportionality requirement between fees and damages and treated the lodestar as the presumptively reasonable fee.
- Justice Powell concurred in the judgment, agreeing that proportionality is not required and emphasizing deference to the district court’s fee determination absent clear error.
- The dissent would have found the fee unreasonable in light of the modest damages and would have reduced the award.

## Legal Principles

- Under 42 U.S.C. § 1988, a fee award is not unreasonable merely because it exceeds the damages recovered.
- The lodestar (reasonable hours multiplied by a reasonable rate) is the starting point and is presumptively reasonable.
- “Results obtained” is a key factor in assessing reasonableness; when plaintiffs obtain excellent results, a fully compensatory fee may be appropriate even if not every contention succeeds.
- Civil-rights litigation may yield important nonmonetary outcomes (including deterrence and institutional effects) that bear on the reasonableness of fees.
- Appellate review of a district court’s fee determination is deferential; reversal is warranted only for clear error or comparable abuse in applying governing standards.

## Conclusion

The Court held that § 1988 does not require attorneys’ fees to be proportional to a civil-rights plaintiff’s damages recovery and upheld a lodestar-based fee award that substantially exceeded damages where the district court found the hours and rates reasonable and the plaintiffs achieved strong litigation success.


City of Riverside v. Rivera, 477 U.S. 561 (1986)