Friday, November 1, 2013

Roberson v. Giuliani case brief

Roberson v. Giuliani case brief summary
346 F.3d 75 (2003)

Plaintiffs sued defendants, city and state officials, alleging seven claims regarding public assistance policies. One claim was dismissed on summary judgment; plaintiffs and the city officials entered into a private settlement agreement resolving the remaining six claims. The United States District Court for the Southern District of New York denied plaintiffs' subsequent motion for attorneys' fees under 42 U.S.C.S. § 1988. Plaintiffs appealed.

Plaintiffs' motion was denied on the ground that plaintiffs were not prevailing parties under the applicable standard. While recognizing that the settlement agreement was a material change in the legal relationship between plaintiffs and the city officials, the district court held that its continuing jurisdiction to enforce the agreement did not constitute a judicial sanctioning of the alternation of the parties' legal relationship such that plaintiffs could be considered prevailing parties.

  • The appellate court disagreed, finding that the district court's retention of jurisdiction carried sufficient judicial approval of the agreement to support an award of attorneys' fees. 
  • Despite the district court's statements that it had not specifically reviewed or approved the terms of the agreement, when the district court retained jurisdiction, it necessarily made compliance with the terms of the agreement a part of its order so that a breach of the agreement was a violation of the order. 
  • Thus, when the district court retained jurisdiction under the approved procedures, it gave judicial sanction to a change in the legal relationship of the parties, regardless of the actual scrutiny applied.

The appellate court vacated the district court's order denying plaintiffs' motion for attorneys' fees and remanded the matter for further proceedings.

Recommended Supplements for Administrative Law Examples & Explanations: Administrative Law, Fourth Edition
Administrative Law and Process: In a Nutshell (Nutshell Series)

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