United States v. Tennessee

The State of Tennessee operated the Arlington Developmental Center, an institutional home for people with mental disabilities. In 1992, the United States sued Tennessee under the Civil Rights of Institutionalized Persons Act alleging that, among other things, Tennessee had failed to provide Arlington’s residents with adequate food, medical care, supervision, and shelter. After a trial on the merits, the district court found that Arlington’s conditions violated the due-process rights of its residents. The court ordered the State to submit a plan to improve conditions there. Since then, People First of Tennessee has presented 19 applications for attorneys’ fees to the district court. Tennessee consented to pay every dollar of fees requested in the first 18 applications filed by intervenors-appellees People First of Tennessee (a total of about $3.6 million, including over $400,000 for the period at issue here). But the State objected to People First’s 19th application, which for the most part sought fees for a contempt motion that the district court had stricken from the docket and that People First never renewed. The 19th application also sought fees for hours that People First’s attorneys had chosen to spend monitoring the State’s compliance with the consent decree, even though the State had already paid $10.6 million in fees to a monitor whom the court had appointed for that same purpose. Despite those circumstances, the district court awarded People First $557,711.37 pursuant to the application, holding that People First had been a “prevailing party” with respect to its contempt motion. The State appealed the district court's award. After review, the Sixth Circuit disagreed with the district court's judgment, reversed and remanded. View "United States v. Tennessee" on Justia Law