Maher v. Gagne

Virginia Gagne (plaintiff) received benefits under a federally funded state-assistance program. Gagne brought a 42 U.S.C. § 1983 action against Edward Maher (defendant), Connecticut’s income-maintenance commissioner, alleging that the program violated the Social Security Act and the Fourteenth Amendment’s Equal Protection and Due Process Clauses. The case was settled. The court entered a consent decree favorable to Gagne without reaching the constitutional issues and awarded Gagne counsel fees under the Civil Rights Attorneys Fee Awards Act (CRAFA), 42 U.S.C. § 1988. The CRAFA permitted a reasonable attorney’s fee to be awarded to the prevailing party in a § 1983 action. The court held that Gagne prevailed because the consent decree afforded substantially all the relief she sought and rejected Maher’s argument that the Eleventh Amendment (which prohibited federal courts from exercising jurisdiction over lawsuits against states) barred the award. Maher appealed, the court of appeals affirmed, and the Supreme Court granted certiorari. Maher argued that Congress authorized attorney-fee awards only in § 1983 actions for constitutional violations, Gagne did not prevail because there was no judicial determination that her rights had been violated, and the Eleventh Amendment barred a federal court from awarding fees against a state for a statutory non-civil-rights claim.