ZINNA v. Congrove

LUCERO, Circuit Judge.

Michael Zinna appeals the district court’s attorneys’ fee award following a successful 42 U.S.C. § 1983 civil rights suit against James Congrove, a county official. On its consideration of the jury verdict favoring Zinna, the district court determined the damage award was nominal and the victory merely technical. It proceeded to award Zinna but $8,000 in attorneys’ fees under § 1988 — $1,000 for each day of an eight-day trial. In light of our jurisprudence applying Farrar v. Hobby, 506 U.S. 103, 116-22, 113 S.Ct. 566, 121 L.Ed.2d 494 (1992) (O’Connor, J., concurring), we…