## Facts

- Connecticut administered a federally funded Aid to Families with Dependent Children (AFDC) program.
- Virginia Gagne, an AFDC recipient who worked, challenged Connecticut regulations that limited credit for work-related expenses, reducing her benefits.
- Gagne alleged the regulations violated the Social Security Act and the Equal Protection and Due Process Clauses of the Fourteenth Amendment.
- She brought suit under 42 U.S.C. § 1983 seeking injunctive and related relief.
- Before a merits judgment, the parties settled, and the federal district court entered a consent decree.
- The consent decree increased standard allowances for work-related expenses and permitted recipients to prove actual expenses exceeding the standard.
- Gagne sought attorney’s fees under 42 U.S.C. § 1988 as a prevailing party in an action to enforce § 1983.

## Issues

1. Whether § 1988 authorizes attorney’s fees in a § 1983 action where the relief is based on enforcing a federal statute such as the Social Security Act.
2. Whether obtaining relief through a settlement embodied in a consent decree can make a plaintiff a “prevailing party” under § 1988.
3. Whether the Eleventh Amendment bars a federal court from awarding § 1988 attorney’s fees against a state in a § 1983 action resolved by consent decree.

## Decision

- The Supreme Court affirmed the fee award.
- The Court held that § 1988 permits fee awards in all § 1983 actions, including those enforcing federal statutory rights such as the Social Security Act.
- The Court held that a plaintiff who obtains substantial, court-ordered relief through a consent decree may be a prevailing party under § 1988.
- The Court held that the Eleventh Amendment did not bar the attorney’s fee award against the state under these circumstances, where substantial constitutional claims supported federal jurisdiction and remained pending until settlement.

## Legal Principles

- Section 1988 authorizes reasonable attorney’s fees to prevailing parties in actions to enforce § 1983, including § 1983 suits predicated on federal statutory violations.
- A consent decree providing material, enforceable relief can confer prevailing-party status for § 1988 purposes even without a merits adjudication.
- When a federal court properly exercises jurisdiction over substantial federal claims in a § 1983 action and awards prospective relief by consent decree, an award of attorney’s fees as costs is not barred by the Eleventh Amendment.

## Conclusion

The Court upheld an attorney’s fee award under § 1988 where the plaintiff obtained significant AFDC-related relief through a consent decree in a § 1983 action enforcing federal statutory rights and alleging substantial constitutional claims, rejecting an Eleventh Amendment bar to such fees.


Maher v. Gagne, 448 U.S. 122 (1980)