Evans v. Jeff D. Case Brief

Facts of the Case

In a complaint in a class action in the United States District Court for the District of Idaho, emotionally and mentally handicapped children alleged that their civil rights under federal and state constitutional and statutory provisions were being violated by the governor and other state officials of Idaho. The complaint, which alleged deficiencies in educational programs and health care services, requested injunctive relief and an award of costs and attorney’s fees, but did not request damages. After a period of negotiations, the parties agreed to a settlement which provided that the injunctive relief requested in the complaint would be granted, that the children’s claim for costs and attorney’s fees would be waived, and that the settlement would be conditioned on the district court’s approval of the waiver of attorney’s fees. Although the children’s attorney, who was employed by a legal aid society, expressed some misgivings about the settlement provision for the waiver of attorney’s fees, the district court approved the entire settlement, including the provision for the waiver of attorney’s fees. The United States Court of Appeals for the Ninth Circuit reversed, holding (1) that when attorney’s fees are negotiated as part of the settlement of a class action, a conflict frequently exists between the class attorney’s interest in compensation and the class members’ interest in relief, and in order to avoid such a conflict, negotiations as to the settlement of the class members’ claim for relief should not be simultaneous with negotiations as to attorney’s fees, in the absence of a showing of unusual circumstances, and (2) that in the present case, in which unusual circumstances were not shown, an agreement on attorney’s fees should not have been a part of the settlement of the class members’ claims for relief, and it was improper to approve a settlement provision for the waiver of attorney’s fees as a condition for the class members’ obtaining injunctive relief ().

Question

Did Congress validly abrogate state sovereign immunity via the Copyright Remedy Clarification Act, which allows authors of original expression to sue states who infringe their federal copyrights?

CONCLUSION

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Case Information

Citation: 475 US 717 (1986)
Argued: Nov 13, 1985
Decided: Apr 21, 1986
Case Brief: 1986