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Jean BOBBITT, Appellant, v. PARAMOUNT CAP MANUFACTURING COMPANY, Appellee
Citations: 942 F.2d 512; 1991 U.S. App. LEXIS 19009; 57 Empl. Prac. Dec. (CCH) 40,982; 56 Fair Empl. Prac. Cas. (BNA) 1064; 1991 WL 156529Docket: 90-2249
Court: Court of Appeals for the Eighth Circuit; August 19, 1991; Federal Appellate Court
Jean Bobbitt appeals a final order from the U.S. District Court for the Eastern District of Missouri, which denied her attorney's fees for services related to her claims against Paramount Cap Manufacturing Company. Bobbitt had settled her claims under Title VII of the Civil Rights Act, the Equal Pay Act, and the Missouri Human Rights Act. The district court ruled that the legal services rendered before and during the Missouri Division of Employment Security (MoDES) proceeding were not necessary to advance her lawsuit to its pre-settlement stage. Bobbitt contended that the constructive discharge issue raised in the MoDES was relevant to her civil rights claims, arguing that the court abused its discretion in denying fees. The factual background includes Bobbitt's employment at Paramount, her discharge from the first shift, and subsequent claims for unemployment benefits, which were determined in her favor by MoDES on the grounds of constructive discharge. Following this, she filed a civil complaint alleging sex discrimination and unequal pay. Bobbitt accepted a settlement offer of $15,000 from Paramount and sought $29,282.50 in attorney's fees, to which Paramount objected. The district court awarded the settlement but denied $7,201 in fees for services rendered before the MoDES proceeding. The Eighth Circuit Court of Appeals reversed the district court's decision and remanded for the award of the disputed attorney's fees. Bobbitt asserts that the district court incorrectly denied compensation for her counsel's work before and during the MoDES proceedings, arguing that not all services rendered before October 26, 1987, were related to MoDES and that the work connected to administrative proceedings was essential for her civil rights actions' success. The court agrees and reverses the district court's decision. Under 42 U.S.C. § 2000e-5(k), a prevailing party in a Title VII action is entitled to reasonable attorney's fees. While the district court has broad discretion in awarding fees, this discretion can be reversed if there is an abuse or misapplication of legal standards. Attorney work on administrative proceedings is compensable if it is useful and necessary for advancing civil rights litigation. The case establishes that fees for research or investigation related to prior proceedings may be recovered if relevant to the civil rights action's success. The constructive discharge issue was pivotal in both the MoDES proceedings and Bobbitt's civil rights claims, indicating that the attorneys' work for MoDES was essential for the civil rights litigation. The $7,201.00 in fees accrued prior to and during the MoDES proceedings is thus compensable. The district court’s judgment is reversed, and the case is remanded for further proceedings.