Richlin Security Service Co. v. Chertoff, 553 U.S. 571 (2008)
Primary Holding
The Equal Access to Justice Act (EAJA) allows a prevailing party in a case against the government to recover attorney's fees, including paralegal services, at the prevailing market rate, rather than limiting recovery to the cost incurred by the attorney's firm.
In the case of Richlin Security Service Co. v. Chertoff, a small security company fought the government over unpaid wages due to a contract mistake. The Supreme Court ruled that if you win a case against the government, you can get back the full cost of your lawyer's fees, including what you paid for paralegal help, based on current market rates, not just what your attorney paid. This means that consumers and small businesses can more easily recover their legal costs when they successfully challenge government decisions, making it fairer for them to stand up for their rights. This case is relevant if you're involved in a legal dispute with the government and win, as it clarifies your right to recover those legal expenses.
AI-generated plain-language summary to help you understand this case
In Richlin Security Service Co. v. Chertoff, the underlying dispute arose when Richlin Security Service Co. (Richlin), a small California business, was contracted by the former Immigration and Naturalization Service (INS) to provide guard services for detainees at Los Angeles International Airport. Due to a mutual mistake, the contracts misclassified Richlin's employees under the Service Contract Act of 1965, leading to a Department of Labor order for Richlin to pay back wages to its employees. In response, Richlin filed a claim with the Department of Transportation’s Board of Contract Appeals seeking reformation of the contracts to obtain additional payments from the government to cover its liabilities. After extensive litigation, Richlin prevailed, and the Board awarded it a favorable decision. Following this victory, Richlin applied for reimbursement of attorney’s fees, expenses, and costs under the Equal Access to Justice Act (EAJA). Specifically, Richlin sought compensation for paralegal services amounting to $45,141.10 for 523.8 hours of work related to the contract claim and $6,760 for 68.2 hours for the EAJA application. The Board granted Richlin's application in part, acknowledging that Richlin met the eligibility requirements and that the government's position was not "substantially justified." However, the Board limited the recovery of paralegal fees to the cost incurred by Richlin's law firm rather than the billed rates, determining a reasonable cost of $35 per hour based on judicial notice of paralegal salaries in the Washington D.C. area. The case progressed to the United States Court of Appeals for the Federal Circuit, which upheld the Board's decision, affirming the limitation on the recovery of paralegal fees. Richlin then sought a writ of certiorari to the Supreme Court, which ultimately reversed the Federal Circuit's decision, addressing the interpretation of the EAJA regarding the recovery of paralegal fees at market rates versus the attorney's cost.
Whether the Equal Access to Justice Act allows a prevailing party in a case against the Government to recover fees for paralegal services at the market rate or only at the cost to the party’s attorney.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- March 19, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Alito
- Damages Awarded
- N/A
- Data Quality
- high
Sole v. Wyner, 551 U.S. 74 (2007)
Consumer LostA plaintiff who obtains a preliminary injunction but is ultimately denied a permanent injunction after a full adjudication on the merits does not qualify as a "prevailing party" under 42 U.S.C. §1988(b) for the purposes of recovering attorney's fees.
Martin v. Franklin Capital Corp., 546 U.S. 132 (2005)
Consumer LostA federal court has discretion to award attorney's fees when remanding a case to state court under 28 U.S.C. § 1447(c), and such an award is appropriate only if the removing party lacked objectively reasonable grounds for believing that the removal was legally proper.
Commissioner v. Banks, 543 U.S. 426 (2005)
Consumer LostWhen a litigant's recovery constitutes income, the portion of that recovery paid to the attorney as a contingent fee is included in the litigant's gross income under the Internal Revenue Code.
Hall Street Associates, L. L. C. v. Mattel, Inc., 552 U.S. 576 (2008)
Consumer LostThe statutory grounds for vacating and modifying arbitration awards under the Federal Arbitration Act are exclusive, and parties cannot contractually expand those grounds.