Farrar v. Hobby

Joseph and Dale Farrar (plaintiffs) owned a school for troubled teens in Texas called Artesia Hall. In 1973, an Artesia Hall student died. A grand jury returned an indictment charging Joseph Farrar with failing to provide medical treatment and timely hospitalization. A temporary injunction closing Artesia Hall was also entered. The lieutenant governor of Texas, William Hobby, Jr. (defendant), ordered the Texas Department of Public Welfare to investigate Artesia Hall. Joseph Farrar sued Hobby and other public officials and sought $17 million. Farrar alleged that he was deprived of liberty and property without due process. A jury found that all the public officials except Hobby conspired against the Farrars but that the conspiracy was not the proximate cause of any injury suffered by the Farrars. The court ordered that the Farrars be awarded nothing and the matter be dismissed. The Farrars appealed, and the court of appeals remanded the case for the lower court to award nominal damages to the Farrars. The lower court awarded the Farrars $1 in nominal damages. Based on the award of nominal damages, the Farrars sought to recover their attorney’s fees under 42 U.S.C. § 1988. The lower court entered an order awarding the Farrars attorney’s fees. The appeals court reversed the fee award, finding that the Farrars were not prevailing parties and therefore not eligible to recover fees under § 1988.