Fox v. Vice

131 S.Ct. 2205 (2011)

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Nature of the Case

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Facts

P and D ran for chief of police in the town of Vinton, Louisiana. D resorted to an assortment of dirty tricks to try to force P out of the race. D sent an anonymous letter to P threatening to publish damaging charges against him if he remained a candidate. D also arranged for a third party to publicly accuse P of using racial slurs and then to file a criminal complaint against P repeating those allegations. And when prosecutors ignored that faux complaint, D leaked it to the press. P won the election. D was subsequently convicted of criminal extortion for his election-related conduct. P filed this suit in Louisiana state court against D and the town of Vinton, also a respondent here. P asserted both state-law claims, including defamation, and federal civil rights claims under 42 U.S.C. § 1983, including interference with his right to seek public office. D removed the case to federal court on the basis of the § 1983 claims. D moved for summary judgment on P's federal claims. P conceded that the claims were “not valid.” The court declined to exercise supplemental jurisdiction over the remaining state-law claims. It remanded the now slimmed-down case to state court for adjudication. D asked the federal court for an award of attorney's fees under § 1988, arguing that P's federal claims were “baseless and without merit.” D submitted attorney billing records estimating the time spent on the whole suit, without differentiating between the federal and state-law claims. The court did not require D to separate out the work his attorneys had done on the two sets of claims. The court, therefore, concluded that D should receive all of the fees he reasonably incurred in defending the suit--a total of $48,681. P appealed. A divided Court of Appeals affirmed. The Supreme Court granted certiorari.