Ali Akbar Muhammad, Also Known as Lee Franklin v. A.L. Lockhart, Director, Arkansas Department of Correction Larry Norris, Assistant Director Marvin Evans, Jr., Warden Robert Clark, Hearing Officer Administrator James Byers, Hearing Officer, Maximum Security Unit, Arkansas Department of Correction Monchie Biram, Hearing Officer, Maximum Security Unit, Arkansas Department of Correction Robert Perry, Major Nuby Courtney, Assistant Warden
Docket: 95-3321
Court: Court of Appeals for the Eighth Circuit; January 15, 1997; Federal Appellate Court
The United States Court of Appeals for the Eighth Circuit upheld the district court's award of attorney's fees, costs, and expenses to Ali Akbar Muhammad under 42 U.S.C. § 1988 following his successful civil rights suit against officials of the Arkansas Department of Correction. Muhammad, representing himself, alleged violations of his procedural due process rights and cruel and unusual punishment due to the use of ill-fitting shoes. The jury ruled in his favor, awarding nominal damages of one dollar against all eight defendants.
Muhammad's appointed counsel requested $5,956.00 in fees and $1,505.40 in costs, linked to the issues presented at trial. The district court awarded $4,500.00 in fees and the full amount for costs. The appellate court affirmed this decision, noting that Muhammad's victory was material and significant, as he prevailed on liability against all defendants rather than just one, distinguishing his case from precedents where the plaintiff's success was minimal. The court referenced Justice O'Connor's criteria from Farrar v. Hobby regarding the significance and extent of relief in cases resulting in nominal damages, concluding that Muhammad’s case met the threshold for a fee award.
Justice O'Connor indicated that fees and costs might be awarded if a judgment serves a public goal. In Mr. Muhammad's case, the jury's general verdict leaves ambiguity regarding which specific claims were successful. However, it is evident that at least one claim was upheld, likely related to a deprivation of due process or cruel and unusual punishment. The Supreme Court has characterized the right to due process as absolute and emphasized the societal importance of its enforcement. Similarly, the right against cruel and unusual punishment evolves with societal standards. The verdict, regardless of its specifics, fulfilled a public goal by promoting government adherence to constitutional obligations. The district court's assessment that Mr. Muhammad achieved a material victory, despite the nominal damages awarded, is upheld, and the court's fee determination is deemed reasonable. The order of the district court is therefore affirmed.
