District of Columbia v. Patterson

667 A.2d 1338, 1995 D.C. App. LEXIS 244, 1995 WL 702619
CourtDistrict of Columbia Court of Appeals
DecidedNovember 30, 1995
Docket93-CV-835, 93-CV-874
StatusPublished
Cited by31 cases

This text of 667 A.2d 1338 (District of Columbia v. Patterson) is published on Counsel Stack Legal Research, covering District of Columbia Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
District of Columbia v. Patterson, 667 A.2d 1338, 1995 D.C. App. LEXIS 244, 1995 WL 702619 (D.C. 1995).

Opinions

STEADMAN, Associate Judge:

At issue in this appeal and cross-appeal is the trial court’s award of attorney’s fees to the plaintiffs in actions filed against the District of Columbia invoking 42 U.S.C. § 1983. The plaintiffs sought to recover property seized by the District pursuant to statutes authorizing the forfeiture of property used in connection with certain drug activities. The actions, inter alia, challenged the constitutionality of the statutes under both the Fourth and Fifth Amendments. Collectively, the actions set forth thirteen different alleged constitutional violations presented by the statutory scheme both on its face and as applied.

Only one of these constitutional claims was sustained by the trial court. The sustained claim was that the claimants had a post-seizure right to a probable cause determination on request. However, only one of the claimants, Patterson, requested such a hearing, at which the court found that in fact probable cause existed for the seizure.

The District on the direct appeal argues that the trial court erred, first, when it found [1341]*1341appellant Patterson to be a prevailing party, because she had only received an interim ruling entitling her to a hearing at which she ultimately lost on the merits, and, second, when it enhanced the attorney’s fee award based on the contingency fee arrangement between plaintiffs and their attorneys. We agree with the District on these two issues.

Plaintiffs1 in the cross-appeal first argue that the trial court erred when it assumed that the plaintiffs had prevailed only on their Fourth Amendment claims. Second, plaintiffs argue that even if they had not prevailed on their other constitutional claims, such claims were “related to” the successful claims and therefore the trial court erred in reducing the fee award to exclude hours spent on the unsuccessful claims. Third, plaintiffs argue that they were entitled to an enhancement for the extended delay in payment. The second and third arguments were not properly preserved below for appeal. With respect to the first argument, we are unable to determine the degree, if any, to which the trial court’s award of fees encompassed not only the Fourth Amendment claims, on which the trial court erroneously concluded plaintiffs had prevailed, but also other constitutional claims on which the plaintiffs claim to have prevailed.

We remand for a redetermination of an award of attorney’s fees consistent with this opinion.

I.

In 1987, Terrie Patterson filed a complaint which, after several amendments, challenged the constitutionality of D.C.Code § 33-552.2 In particular, the complaint, based in this regard on 42 U.S.C. § 1983,3 alleged that the statute violated the Fourth, Fifth, Sixth and Eighth Amendments. She sought to recover possession of her seized car pursuant to the terms of the statute barring such seizures as against innocent owners, and to recover damages for loss of use, property damages and consequential damages.

Patterson later moved for a class certification, which was denied. Several consolidated claims4 and parties were added to this action; they involved individual claims on behalf of the other plaintiffs regarding seizures of their cars under D.C.Code § 33-552(a)(4), or seizures of cash under D.C.Code § 33-552(a)(6).5

In an amended order dated January 6, 1989, Patterson v. District of Columbia, 117 Daily Wash.L.Rptr. 741 (D.C.Super.Ct.1989), the trial court held that § 33-552 did not, on its face, violate the Fifth Amendment’s Due Process Clause or the Sixth or Eighth Amendments. The court noted, however, that the statute did not provide for a prompt post-seizure procedure. In particular, once the property was seized, no process was is[1342]*1342sued or filed during the time that Corporation Counsel decided whether to institute a forfeiture proceeding. If Corporation Counsel decided to pursue forfeiture, a libel of information was filed in Superior Court, and the case proceeded under the Superior Court Rules of Civil Procedure. Hence, property could possibly be held for up to two years without a judicial hearing in which an owner could present defenses, such as a lack of knowledge of the use of the property for an illegal purpose. See D.C.Code § 33-552(a)(4).6 Accordingly, the trial court held that under the Fourth Amendment, “claimants from whom property has been seized have a right to a probable cause determination, post-seizure at their request.” On May 12, 1989, Patterson moved for such a hearing.7 A hearing was held on December 21, 1989, at which the court found that there was indeed probable cause for the seizure.

The court order of January 6,1989, however, did not address the claims that the procedures employed did not provide adequate pre- and post-seizure notices assertedly required by the Fifth Amendment. These claims had been the subject of a summary judgment motion filed by plaintiffs Morris Hinton and Lennox Layne, which was never acted upon. In the spring of 1992, a settlement was reached respecting these claims of inadequate notice.8

In November of 1992, the trial court issued its first order relating to attorney’s fees.9 The order held that the plaintiffs were prevailing parties in the litigation, and thus entitled to fees under 42 U.S.C. § 1988 (1988 & Supp. V 1993).10 The court held that the plaintiffs had prevailed on their Fourth Amendment claims because the “declaratory judgment requiring a probable cause hearing prior to forfeiture was a judgment in petitioners’ favor and affected the conduct between these parties.” Furthermore, the court, citing District of Columbia v. Jerry M., 580 A.2d 1270 (D.C.1990), held that the parties who had settled their claims were also prevailing parties. Therefore, counsel were ordered to submit the fees and costs “incurred as a result of litigating the constitutional portions of plaintiffs’ cases.” The plaintiffs’ subsequent submission of attorney’s fees sought $76,29011 for Brenda Grantland (610.3 hours at $125 per hour), and $22,540 for Landon Dowdey (128.8 hours at $175 per hour).12

In an order dated May 19, 1993, the trial court awarded Grantland $26,623.03 and Dowdey $7,513 in fees. The court began with the total number of hours claimed for each attorney and then reduced that figure by one-half “to more accurately reflect the hours spent on the Fourth Amendment issues,” and to exclude those hours spent on other aspects of the litigation.

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Bluebook (online)
667 A.2d 1338, 1995 D.C. App. LEXIS 244, 1995 WL 702619, Counsel Stack Legal Research, https://law.counselstack.com/opinion/district-of-columbia-v-patterson-dc-1995.