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Hensley v. Eckerhart

461 U.S. 424 (1983)

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Hensley v. Eckerhart

United States Supreme Court

461 U.S. 424 (1983)

Facts

A class of patients involuntarily confined at a state mental hospital (the patients) (plaintiffs) sued the hospital and its employees (defendants) in federal district court, alleging the hospital’s treatment and conditions were unconstitutional. Specifically, the patients claimed six areas contained constitutional violations: physical environment, treatment plans, least-restrictive environment, communication privileges, seclusion and restraint, and staffing. Although the district court held that the first five areas were unconstitutional, the court held that the staffing levels were adequate. The patients filed a request for attorney’s fees for all the hours spent on litigating the case, including the unsuccessful claim regarding staffing levels. The district court slightly reduced the amount of the fees for one attorney to account for the attorney’s inexperience and lack of good record-keeping. Otherwise, the district court granted the request for the attorney’s fees, concluding that the patients were the prevailing party and therefore could recover for unsuccessful claims. The court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Powell, J.)

Concurrence (Burger, C.J.)

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