Steward v. County of Santa Clara

Background

Aaron Steward filed claims under 42 U.S.C. § 1983, a federal civil-rights law, alleging excessive force under the Fourteenth Amendment. He also brought claims under California Civil Code section 52.1, known as the Bane Act, and for intentional infliction of emotional distress. After summary judgment, the remaining claims concerned Deputy Rico West’s alleged November 7, 2016 contraband search and July 12, 2017 altercation, and Deputy Christopher Graham’s alleged July 12, 2017 “rough ride.” The parties waived a jury trial, and the case went to a court trial from April 26 through April 29, 2021.

The court found for Steward on his claims against West arising from the July 12, 2017 altercation, but found against him on the claims concerning Graham’s alleged “rough ride.” The court found that West used unreasonable excessive force, that Steward did not actively resist, and that West violated Steward’s rights under the Fourteenth Amendment and the Bane Act. It awarded Steward $10,000 in compensatory damages and $1,000 in punitive damages. The court had previously stated that Steward would receive attorneys’ fees only for his claims against West concerning the altercation because of his limited success.

Fee request and ruling

Steward requested $360,235 in attorneys’ fees and a 2.0 multiplier for the Bane Act claim. His lawyers submitted declarations and billing records, and Richard Pearl submitted an expert declaration addressing the reasonableness of counsel’s hourly rates. Counsel reported deducting approximately 78.8 hours for time spent on unsuccessful claims. The defendants argued for an 80% reduction, disputed any multiplier, challenged the lawyers’ rates, and claimed the case was overstaffed; they proposed an award of no more than $30,650.

The court reduced Steward’s lodestar—the starting fee calculation based on reasonable hours and rates—by 50%, resulting in $180,117.50. It held that the reduction reflected Steward’s limited success while accounting for the factual relationship between the successful altercation claims and unsuccessful claims, including claims involving inadequate training, the “rough ride,” and alleged consequences of being labeled the aggressor. The court declined to reduce the award further because of the amount of damages, the complexity of the case, the extensive discovery, alleged overstaffing, or the lawyers’ hourly rates. Judge Susan Illston therefore granted the motion for attorneys’ fees in part and awarded $180,117.50.