Friday, December 6, 2013

Evans v. Jeff D. case brief

Evans v. Jeff D. case brief summary
475 U.S. 717 (1986)


CASE SYNOPSIS
Petitioners challenged a decision from the United States Court of Appeals for the Ninth Circuit, which invalidated a fee waiver contained in a settlement of a class action suit on the basis that such fee waiver violated the Civil Rights Attorney's Fees Awards Act of 1976, 42 U.S.C.S. § 1988.

CASE FACTS
Respondents brought a class action lawsuit on behalf of handicapped children in the care of petitioners, state officials. Petitioners offered a settlement that equaled or exceeded what respondents reasonably expected to obtain through trial, but conditioned the settlement on a waiver of attorney's fees. While the district court approved the settlement, the court of appeals granted an emergency stay that invalidated the fee waiver and left standing the remainder of the settlement.

DISCUSSION

  • On review, the court addressed whether the Civil Rights Attorney's Fees Awards Act of 1976, 42 U.S.C.S. § 1988, required the district court to disapprove the settlement because it was expressly conditioned on waiver of statutory eligibility for attorney fees. 
  • The court concluded that Congress did not command that all such settlements must be rejected, but left the decision to the discretion of the district courts to appraise the reasonableness of particular class-action settlements on a case-by-case basis. 
  • On the facts of record in this case, the court was satisfied that the district court did not abuse its discretion by approving the fee waiver, and as a result, the decision below was reversed.

CONCLUSION
The lower court's decision, which invalidated the fee waiver portion of a settlement of a civil rights class action case, was reversed as a result of the court's finding that such waiver was not prohibited by statute and the district court did not abuse its discretion by approving the waiver as part of the settlement.


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