## Facts

- Anthony Lee sued American Eagle Airlines, Inc. under Title VII and 42 U.S.C. § 1981 alleging a racially hostile work environment and race-based termination.
- After a roughly 14-day jury trial, the jury found for Lee on the hostile work environment claim and against him on the discriminatory termination claim.
- The jury awarded Lee $300,000 in compensatory damages and $650,000 in punitive damages.
- As the prevailing party on the hostile-environment claim, Lee moved for attorney’s fees and costs under 42 U.S.C. § 1988 and related fee-shifting authority, seeking $1,611,910.50 and asserting hourly rates around $300 for his attorneys.
- The court observed, and the defendant alleged, repeated unprofessional and disruptive conduct by plaintiff’s counsel during trial, including combative interactions, disrespectful courtroom demeanor, and a dispute involving the court reporter.
- Because post-trial submissions sharply conflicted about the extent of the misconduct, the court held an evidentiary hearing and took testimony to make factual findings relevant to the fee request.

## Issues

1. Whether a district court may consider a prevailing plaintiff’s counsel’s unprofessional, disruptive, and trial-prolonging conduct when determining a “reasonable” attorney’s fee under 42 U.S.C. § 1988.
2. Whether the requested hours and rates were reasonable under the lodestar method given the case’s staffing, complexity, degree of success, and counsel-caused inefficiencies.

## Decision

- The court granted the motion for attorney’s fees and costs in part and denied it in part.
- The court held that counsel’s unprofessional and disruptive conduct was a proper consideration in assessing the reasonableness of the requested fee.
- Applying the lodestar method, the court reduced the claimed hourly rate and excluded or cut hours it found excessive, unnecessary, duplicative, or attributable to counsel’s own conduct that prolonged proceedings.
- The court awarded a substantially reduced fee compared to the approximately $1.6 million sought.

## Legal Principles

- Under 42 U.S.C. § 1988, a prevailing civil-rights plaintiff is entitled to recover a “reasonable” attorney’s fee, not necessarily the amount billed.
- The lodestar method (reasonable hours × reasonable rate) is the usual starting point, and the court must exclude time that is excessive, redundant, or otherwise unnecessary.
- Counsel conduct that prolongs proceedings or reduces the value of legal services may be treated as relevant to the reasonableness of compensable hours and to whether the lodestar should be reduced.
- A court may reduce fees to prevent shifting to the opposing party the costs of inefficiency or self-inflicted litigation burdens, even when the plaintiff prevailed on a significant claim.

## Conclusion

The court held that fee-shifting under § 1988 does not require compensating a prevailing party for inflated or avoidable attorney time, and it substantially reduced the fee request because counsel’s behavior and litigation choices increased hours beyond what was reasonably necessary and diminished the compensable value of the work.


Lee v. Am. Eagle Airlines, Inc., 93 F. Supp. 2d 1322 (S.D. Fla. 2000)