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Huntington Branch NAACP v. Town of Huntington

Citations: 762 F. Supp. 528; 1991 U.S. Dist. LEXIS 5817; 1991 WL 69433Docket: No. CV-81-0541

Court: District Court, E.D. New York; April 29, 1991; Federal District Court

Narrative Opinion Summary

The case involves a dispute over the award of expert witness fees in light of a Supreme Court decision. The plaintiffs initially sought recovery of these fees under 42 U.S.C. § 1988, following a favorable interpretation by District Judge Glasser. However, the Supreme Court's ruling in West Virginia University Hospitals, Inc. v. Casey, which limited expert witness fees to $30 per day under 28 U.S.C. § 1821(b), prompted the defendants to seek a reduction in the plaintiffs' award by $19,889.80. The plaintiffs opposed this adjustment, arguing the original agreement was comprehensive and statutory language differences rendered the Supreme Court decision inapplicable. The court disagreed, finding no significant distinction in the statutory language and applied the Supreme Court's limitation. Consequently, the court mandated that the defendants expedite processes for a housing project and comply with relevant regulations, while retaining jurisdiction over the case. The defendants were ordered to pay reasonable attorney fees and costs to the plaintiffs, minus the reduced expert witness fees. This case underscores the constraints imposed by federal statutes on court awards absent specific statutory or contractual authorization.

Legal Issues Addressed

Authority of Federal Courts in Reimbursing Expert Witness Fees

Application: Federal courts are bound by 28 U.S.C. § 1821(b) for expert witness fees unless there is a specific statutory or contractual provision to the contrary.

Reasoning: In West Virginia University Hospitals, the Court reaffirmed its ruling from Crawford Fitting Co. v. J.T. Gibbons, Inc., establishing that a federal court is limited by 28 U.S.C. § 1821(b) regarding reimbursement for expert witness fees, unless there is a contract or explicit statutory authority allowing otherwise.

Award of Expert Witness Fees Under 28 U.S.C. § 1821(b)

Application: The court reduced the award for expert witness fees to $30 per day following the Supreme Court's decision, despite previous agreements.

Reasoning: After the Supreme Court's decision on March 19, 1991, which limited expert witness fees to $30 per day under 28 U.S.C. § 1821(b), the parties agreed to a final judgment, which included a stipulation for the defendants to pay reasonable attorney fees and costs.

Court's Retention of Jurisdiction to Enforce Judgments

Application: The court retained jurisdiction to ensure compliance with its orders and previous judgments related to the housing project.

Reasoning: The Court retains jurisdiction to enforce this judgment and a previous partial final judgment from May 16, 1989.

Interpretation of Statutory Language in Awarding Costs

Application: The court found no significant legal difference in the statutory language between 'attorney's fees and costs' and 'attorney's fees as part of the costs'.

Reasoning: The distinction between 'attorney's fees and costs' versus 'attorney's fees as part of the costs' was deemed legally insignificant by the court.