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Maine v. Thiboutot

448 U.S. 1 (1980)

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Maine v. Thiboutot

United States Supreme Court

448 U.S. 1 (1980)

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Facts

Lionel and Joline Thiboutot (plaintiffs) were married and had eight children, three of which were Lionel’s from a prior marriage. The couple sued the state of Maine and its Commissioner of Human Services (defendants) after the state notified the couple that the welfare benefits for Lionel’s three children would decrease, because the calculation of benefits would no longer involve an allowance for the money spent on the other five children. The complaint was brought in the Maine Superior Court and alleged deprivation of welfare benefits under the federal Social Security Act, 42 U.S.C. § 602(a)(7), and a civil rights violation under 42 U.S.C. § 1983 for themselves and others similarly situated. The Thiboutots also claimed attorney’s fees under the Civil Rights Attorney’s Fees Act, 42 U.S.C. § 1988. The trial court awarded retroactive benefits to the Thiboutots and all eligible class members and enjoined enforcement of the challenged rule. The court, however, did not award attorney’s fees. The state did not appeal, but the Thiboutots appealed the fee ruling. The Supreme Judicial Court of Maine held that the Thiboutots were not entitled to attorney’s fees under state law, but were entitled to fees under 42 U.S.C. § 1988. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Brennan, J.)

Dissent (Powell, J.)

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