Johnson v. Blum, 58 N.Y.2d 454 (1983)
In civil rights cases brought under 42 U.S.C. § 1983, a prevailing party should ordinarily recover attorney’s fees unless special circumstances would render such an award unjust.
Summary
Johnson and Stone challenged the denial of public assistance for their children based on a state directive that treated applicants differently from recipients regarding the disposal of assets. The New York Court of Appeals addressed the standard for awarding attorney’s fees under 42 U.S.C. § 1988 to prevailing parties in civil rights cases. The court held that attorney’s fees should be awarded unless special circumstances would make the award unjust, adopting the Newman-Northcross rule. The court rejected the argument that the availability of public funding for the legal service representing the petitioners or the personal nature of the relief obtained constituted such special circumstances.
Facts
Petitioners Johnson and Stone were denied public assistance for their minor children because they refused to dispose of automobiles, which the respondents considered non-essential assets. This denial was based on Administrative Directive 80ADM-1, which differentiated between public assistance applicants and recipients. The directive stated that recipients’ assistance could not be discontinued for refusing to dispose of non-essential assets unless a lack of need was demonstrated, but applicants faced ineligibility for the entire family if they failed to dispose of available resources. Johnson and Stone challenged this directive, arguing it violated the equal protection clauses of the U.S. and New York Constitutions.
Procedural History
Special Term initially ordered the respondents to provide assistance to the minors, declaring the directive unconstitutional but denied the petitioners’ request for attorney’s fees without explanation. The Appellate Division affirmed, stating that awarding counsel fees under 42 U.S.C. § 1988 was discretionary. The New York Court of Appeals then reviewed the case to determine the appropriate standard for awarding attorney’s fees under Section 1988.
Issue(s)
Whether the decision to grant attorney’s fees to a prevailing party under 42 U.S.C. § 1988 is entirely discretionary, or whether a prevailing party should ordinarily recover fees unless special circumstances would render such an award unjust.
Holding
No, the decision to grant attorney’s fees is not entirely discretionary; the prevailing party should ordinarily recover reasonable fees unless special circumstances would render such an award unjust, because this standard aligns with the intent of Congress in enacting Section 1988 to facilitate access to the judicial process for victims of civil rights violations.
Court’s Reasoning
The court reasoned that Section 1988 was enacted to enforce 42 U.S.C. § 1983, which imposes liability on those who deprive citizens of their federal rights under color of law. The court adopted the Newman-Northcross rule, stating that a prevailing party should ordinarily recover attorney’s fees “unless special circumstances would render such an award unjust” (Newman v. Piggie Park Enterprises, 390 U.S. 400, 402; Northcross v. Memphis Bd. of Educ., 412 U.S. 427, 428). Citing legislative history, the court emphasized Congress’s intent to facilitate access to the judicial process for civil rights victims who might otherwise be unable to afford it. The court noted that awarding attorney’s fees helps ensure that those who violate fundamental laws do not proceed with impunity. It rejected the argument that the petitioners’ counsel being a publicly funded legal service organization or that the relief afforded being personal to the petitioner constituted special circumstances justifying the denial of fees, citing Washington v. Seattle School Dist. No. 1, New York Gaslight Club v. Carey, and other cases. The court emphasized that Section 1988 created a system of “private attorneys general” to vindicate national policy and that the statute should be construed broadly. Therefore, the respondents had to establish the special circumstances that militated against awarding fees, which they failed to do.