Bravo v. City of Santa Maria

Under 42 U.S.C. § 1988, examining a plaintiff’s success in acquiring a settlement against a defendant arising out of the same facts is appropriate when awarding attorneys' fees.

The Bravo family alleged that their constitutional rights were violated when the Santa Maria Police Department (SMPD) raided their house while look for a potential suspect in a shooting. That night, police officers prepared to carry out warrants against eight individuals. However, one of the individuals, Javier Bravo Jr., was still in prison. The affidavits did not include important information such as the date of the offenses, or that Javier Jr. was sentenced to prison seven months before the shooting incident, or that he could still be in prison. Despite this, the SMPD along with the Santa Barbara Police Department conducted a search of the Bravo residence. The SWAT team knocked the door open, threw two flashbang grenades inside, and ordered the Bravo family to lie on the floor. During the search, the SWAT were informed that Javier Jr. was in prison. Subsequently, the Bravos filed suit alleging a violation of the Fourth and Fourteenth Amendments. SMPD responded that the Bravo’s family settlement with the city of Santa Barbara should offset their damages and no suit should be brought. On appeal, the court looked into whether the damages awarded by one defendant should offset the others damages. Damages under 42 U.S.C. § 1983 are calculated by the lodestar method which first examines what constituted reasonable attorney fees, and second, the lodestar is adjusted upward or downward using a variety of factors. According to the court, there was two benefits in the record. First, the litigation highlighted a serious flaw with the SMPD's methods. Second, a district court may consider damages of other defendants in evaluating the plaintiffs’ degree of success. The attorney awards were affirmed because of the public benefit arising from the litigation. Further, the court concluded that Santa Maria is entitled to an offset, thus reversing the District Court's refusal to offset. AFFIRMED in part, REVERSED in part, and REMANDED for determination of costs.