Guillory v. Hill

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LeRoy Guillory and 11 other plaintiffs appealed the denial of their 42 U.S.C. 1988 motion for attorney fees as prevailing parties in their civil rights claim against defendant Orange County Sheriff’s Department Investigator Michele Hill. In 2007, following a huge Halloween party, 100 special weapons and tactics (SWAT) officers raided the mansion where the party had taken place. The SWAT team forcibly detained plaintiffs and restrained their hands behind their backs with zip ties. About an hour later, Hill and a team of around 40 officers entered the mansion to conduct a warrant-based search for evidence of illegal gaming. Hill coordinated the search. At various times that day, she interviewed and released each plaintiff separately. Plaintiffs sued Hill and other defendants for allegedly violating plaintiffs’ civil rights under 42 U.S.C. 1983. Eventually, “several defendants including the various SWAT teams, unnamed ‘Doe’ police officers, and County of Orange defendants dropped out, either by plaintiffs’ failure to name the ‘Doe’ defendants or by settlement or summary adjudication,” leaving Hill as the sole remaining defendant. At the close of evidence, the trial court granted Hill’s motion for a directed verdict. On appeal from the first trial, the Court of Appeal reversed the directed verdict solely as to plaintiffs’ “section 1983 claims based on the prolonged detention of the plaintiffs” after the search ended. The Court affirmed, however, the directed verdict on plaintiffs’ other constitutional claims, “including the SWAT team and other officers’ allegedly excessive force in entering and securing the premises” and “restraining the detainees with excessive force before Hill questioned them.” The jury awarded damages to nine plaintiffs; the jury found in Hill’s favor on the three remaining plaintiffs. Plaintiffs contended the trial court abused its discretion when it denied their request for attorney fees. The Court of appeal found, "in light of plaintiffs’ minimal success and inflated fee request," the trial court properly exercised its discretion to deny their section 1988 motion. Plaintiffs originally sought over $1 million in damages but ultimately obtained an award of less than $5,400. Plaintiffs then moved for almost $3.8 million in attorney fees in a 392-page motion containing, in the trial court’s words, “bloated, indiscriminate,” and sometimes “‘cringeworthy’” billing records. View "Guillory v. Hill" on Justia Law