Aponte v. City of Chicago

Dist. Ct. did not err in awarding plaintiff zero attorney fees after jury awarded plaintiff $100 on one of eight claims against four defendants in section 1983 action alleging that defendants violated plaintiff’s 4th Amendment rights when carrying out search warrant on plaintiff’s home. Under Farrar, 506 US 103, Dist. Ct. may award zero fees when plaintiff had received only minimal damages, and record established that zero fees was reasonable, even though plaintiff sought $450,000 in attorney fees, where: (1) plaintiff sued four defendants and sought over $100,000 in compensatory damages; (2) instant $100 award represented only .4% of plaintiff’s requested damages against said defendant; and (3) instant $100 award could not be viewed as compensatory since it did not correspond to any itemized property damages sought by plaintiff. Ct. further noted that plaintiff’s victory on just one of eight claims was not significant, and that instant minimal monetary award reflected mere personal victory that had no broader import to public.