461 U.S. 424 (1983)
In 1972, respondents, representing all persons involuntarily confined at the Forensic Unit of the Fulton State Hospital in Fulton, Missouri, filed a three-count complaint in the District Court for the Western District of Missouri against petitioners, who are officials at the Forensic Unit and members of the Missouri Mental Health Commission.1 Count I challenged the constitutionality of treatment and conditions at the Forensic Unit. Count II challenged the placement of patients in the Biggs Building without procedural due process. Count III sought compensation for patients who performed institution-maintaining labor.2
Count II was resolved by a consent decree in December 1973. Count III largely was mooted in August 1974 when petitioners began compensating patients for labor pursuant to the Fair Labor Standards Act.3 In April 1975 respondents voluntarily dismissed the lawsuit and filed a new two-count complaint. Count I again related to the constitutionality of treatment and conditions at the Forensic Unit. Count II sought damages based on the Thirteenth Amendment for the value of past patient labor. In July 1976 respondents voluntarily dismissed this backpay count. Finally, in August 1977 respondents filed an amended one-count complaint specifying the conditions that allegedly violated their constitutional right to treatment.4
In August 1979, following a three-week trial, the District Court held that an involuntarily committed patient has a constitutional right to minimally adequate treatment and found constitutional violations in five of six general areas, including physical environment, individual treatment plans, least restrictive environment, visitation, telephone, and mail privileges, and seclusion and restraint.5 With respect to staffing, the sixth general area, the District Court found that the Forensic Unit's staffing levels, which had increased during the litigation, were minimally adequate.6 Petitioners did not appeal the District Court's decision on the merits.7
In February 1980 respondents filed a request for attorney's fees for the period from January 1975 through the end of the litigation.8 Their four attorneys claimed 2,985 hours worked and sought payment at rates varying from $40 to $65 per hour, amounting to approximately $150,000, and also requested that the fee be enhanced by 30 to 50 percent.9 The District Court determined that respondents were prevailing parties and awarded a fee of $133,332.25 after reducing the number of hours claimed by one attorney by 30 percent and declining to adopt an enhancement factor.10 The Court of Appeals for the Eighth Circuit affirmed on the basis of the District Court's memorandum opinion and order.11 The Supreme Court granted certiorari.12
Whether a partially prevailing plaintiff may recover an attorney's fee for legal services on unsuccessful claims?13
Under 42 U.S.C. § 1988 a plaintiff must be a prevailing party to recover fees. When claims share a common core of facts or related legal theories, the district court should focus on the significance of the overall relief obtained rather than mechanically apportioning hours between winning and losing claims.14
Yes. Respondents filed a three-count complaint in 1972 and an amended one-count complaint in 1977 that challenged conditions at the Forensic Unit and shared a common core of facts regarding treatment and institutional practices.15 After the three-week trial in August 1979 the District Court found constitutional violations in five of six general areas while finding staffing levels minimally adequate. The interrelated nature of the claims means work on the unsuccessful staffing issue contributed to the overall success achieved on the remaining claims.16
A partially prevailing plaintiff may recover an attorney's fee for legal services on unsuccessful claims when those claims are related to the successful ones.17
Related opinions on this issue
Chief Justice Burger filed a concurring opinion. He read the Court's opinion as requiring that when a lawyer seeks to have his adversary pay the fees of the prevailing party, the lawyer must provide detailed records of the time and services for which fees are sought.18 The attorney must establish by clear and convincing evidence the time and effort claimed and show that the time expended was necessary to achieve the results obtained.19
Burger stressed that a claim under section 1988 differs from a bill to a client because there is no relationship of trust between adverse parties.20 Therefore extensive documentation is necessary for a neutral judge to evaluate the fee request fairly.21
Whether the district court must consider the relationship between the extent of a plaintiff's success and the amount of the fee award when determining a reasonable attorney's fee under 42 U.S.C. § 1988?22
The extent of a plaintiff's success is a crucial factor in determining the proper amount of an award of attorney's fees under 42 U.S.C. § 1988. Where the plaintiff achieved only partial or limited success, the product of hours reasonably expended times a reasonable hourly rate may be excessive. The district court should award only the amount of fees reasonable in relation to the results obtained.23
Yes. The District Court determined respondents were prevailing parties and awarded $133,332.25 after reducing one attorney's hours by 30 percent and declining enhancement.24 The opinion stated only that the extent of the relief clearly justifies a reasonable fee.25 It did not examine whether that fee was reasonable given success on five of six areas after the 1979 trial and failure on the staffing claim that petitioners asserted consumed 70 to 80 percent of attorney time.26
The district court must consider the relationship between the extent of a plaintiff's success and the amount of the fee award when determining a reasonable attorney's fee under 42 U.S.C. § 1988.27
Related opinions on this issue
Joined by Justices Marshall, Blackmun, And Stevens
Justice Brennan concurred in part and dissented in part.28 He agreed that the extent of success is a crucial factor in fee calculations under section 1988.29 Brennan concluded that the District Court had already made a commendable effort to explain the fee award in detail.30
The award fell well within the court's zone of discretion.31 Vacating the judgment and remanding would only invite losing defendants to prolong litigation over fees after the merits have been decided.32 He emphasized that appellate courts should affirm promptly when the fee award is reasonable in light of the facts and results.33