Willis W. Corbett Mary Singleton Lillian Juanita Welker Judy Dabler John McGowen Steve Buss and Dwight M. Scharnhorst v. Richard W. Sullivan Linda M. Locke Pamela S. Wright and Barbara A. Enneking, Being the Members of and Constituting the Board of Election Commissioners of St. Louis County, Missouri St. Louis County, Missouri, Intervenor
Docket: 03-1062
Court: Court of Appeals for the Eighth Circuit; December 23, 2003; Federal Appellate Court
Representatives of the Republican Party, known as the Corbett plaintiffs, challenged the District Court's awarded attorney's fees in a case regarding the apportionment of St. Louis County's governing body. They contended that the District Court failed to adequately explain its decision. The Court of Appeals affirmed the District Court's award. The case arose from a failure in the political process, specifically concerning the St. Louis County Council, which is required by its Charter to be divided into seven single-member districts. After the 2000 census, redistricting was mandated, and a Reapportionment Commission was appointed with a deadline of December 28, 2001, to complete the task. The Charter lacked provisions for extending the Commission's mandate or addressing its inaction.
Historically, when previous commissions failed, federal judges intervened to draw the district lines. Anticipating another failure, the Republicans filed suit on December 21, 2001, arguing that the existing districts violated the "one person, one vote" principle and the Voting Rights Act due to demographic changes resulting in unequal populations. The Democratic Party and the St. Louis NAACP intervened on the plaintiffs' side, with the primary contention being the appropriate remedy rather than the validity of the existing district plan.
The defendants, members of the Board of Election Commissioners, maintained neutrality during the trial, presenting no evidence or cross-examinations. The dispute centered around the proposed district maps: the Republicans submitted two, while the Democrats submitted one, and the NAACP initially proposed a plan but withdrew it in favor of a Republican map. Ultimately, the District Court, wary of political implications and recognizing the potential for gerrymandering in all proposals, opted to create its own plan focused solely on population equality, compactness, contiguity, and compliance with the Voting Rights Act.
All three plaintiff-side parties sought attorney fees after prevailing on a constitutional claim regarding County Council district lines. The District Court noted that litigation was deemed an appropriate method for establishing district lines, leading to fee awards. The NAACP received $28,598.25, the Democrats received $68,511, and the Republicans requested $196,451.50 but were awarded the same amount as the Democrats due to a finding that their representation was equivalent. The Court awarded different amounts for allowable expenses and taxable costs between the parties. The Republicans appealed, arguing that the District Court failed to establish a "lodestar" amount and unreasonably deviated from it. The appellate court upheld the District Court's fee award, stating that the District Court's decisions on attorney fees are reviewed for abuse of discretion, while legal rulings are reviewed de novo. The appellate court recognized the District Court's expertise in assessing counsel's work. Although the Republicans contended that the District Court did not explicitly state a lodestar amount, the Court’s award to the Democrats included an implicit determination of reasonable hours and rates, which was deemed sufficient for review. The Court's rationale for equal fees indicated an assessment that the representation provided by both parties was of equal value, aligning with the lodestar analysis' requirements for determining reasonable hours and rates.
The Court noted that some time billed by the Republican lawyers was unnecessary and highlighted that the Corbett plaintiffs employed lawyers with higher hourly rates compared to the Democrats, which the Court deemed excessive. The District Court's determination of a reasonable fee was deemed appropriate, supported by the principle that a plaintiff's success significantly influences fee reasonableness. The District Court established a lodestar figure for the Republicans, which was accepted as reasonable. Furthermore, the Court observed that the NAACP was awarded $28,598.25, the full amount requested, and that the Corbett plaintiffs argued that their efforts saved the NAACP time and costs, suggesting that the Republicans' fees should reflect this saving. However, the Court found this argument unpersuasive, stating that while the Corbett plaintiffs' efforts may have reduced the NAACP's lawyer's workload, it did not justify altering the fee outcome. The Court concluded that granting the Corbett plaintiffs further compensation would result in an unjust windfall, affirming the District Court's judgment.
