Vega v. Chicago Park District

Dist. Ct. did not err in awarding plaintiff’s counsel $1,006,592 and $218,221.09 in initial and supplemental attorneys’ fee requests in plaintiff's successful Title VII claim. Record showed that, with respect to initial fee award, Dist. Ct. evaluated plaintiff’s 200-plus page, fee request spreadsheet, line-by-line and struck dozens of entries that it found were plainly insufficient before reducing total fee request by 5 percent. Moreover, Dist. Ct.’s analysis was consistent with case law that provided that once petitioning party provides evidence of proposed fees’ reasonableness, burden shifted to other party to demonstrate awards’ unreasonableness. Ct. also rejected defendant’s claim that Dist. Ct. improperly awarded fees for plaintiff’s unsuccessful retaliation and section 1983 claims, where: (1) plaintiff’s counsel voluntarily eliminated some entries that concerned only claims on which plaintiff did not prevail; and (2) Dist. Ct. could properly find that no deduction should occur where plaintiff’s unsuccessful claims had common core of facts or factual nexus with claim on which plaintiff prevailed. Also, Dist. Ct. could use plaintiff’s counsel’s current billing rate, as opposed to her historical rate, where Dist. Ct. could properly compensate for instant long delay in counsel’s payment. Dist. Ct. also did not err in its calculation of instant tax-component award, even though Dist. Ct. included $300,000 compensatory damages award to calculate plaintiff’s effective tax rate and considered tax returns that had redacted entries.