At issue was whether Layman Lessons was entitled to attorney fees and costs after prevailing in a RLUIPA action wherein it secured injunctive relief. Two weeks after filing its complaint the court entered an agreed order for an arrangement which provided that the City of Millersville was temporarily enjoined from enforcing against Layman Lessons a proposed zoning ordinance. The parties spent nearly a year conducting discovery and thereafter Layman Lessons withdrew its request for compensatory damages and demand for a jury trial. Rather, it filed its motion for summary judgment seeking injunctive and declaratory relief, nominal damages and attorney fees. The court granted summary judgment on the RLUIPA and Due Process claims, and awarded nominal damages.
The question presented was whether attorney fees would be allowed given the award of nominal damages. In applying the appropriate legal standard to the present case, that is, the degree of success compared to the relief sought; the significance of the legal issues on which the plaintiff prevailed; and whether plaintiff’s success accomplished some public goal, the court determined that an award of attorney fees was warranted. In particular, the court concluded that the case was not the “usual” civil rights case in which a nominal fee award is indicative of a merely nominal or pyrrhic victory. Rather, the court concluded that Layman Lessons’ succeeded in light of its primary objectives of the litigation: it prevailed on significant legal issues and its success accomplished some public goal beyond simply “occupying the time and energy of counsel, the court and the client.” Accordingly, the Court found that a full compensatory fee was warranted.
Layman Lessons, Inc. v. City of Millersville, Tennessee, 2008 WL 1924223 (MD TN, 4/29/2008).
Special thanks to Daniel Dalton, Esq. of Tomkiw Dalton in Royal Oak, Michigan for providing this abstract.
Read what the ReligionClause Blog had to say here: http://religionclause.blogspot.com/2008/05/attorneys-fees-awarded-in-rluipa-case.html
