Richardson v. City of Chicago

Off-duty Officer Macon argued with Richardson about Macon’s former girlfriend. Macon fired his gun at Richardson but missed. When on-duty officers arrived, Macon said that Richardson had struck him with a baseball bat. Richardson was arrested and charged with assault and battery. After the charges were dismissed, Richardson filed suit, with 39 claims under 42 U.S.C. 1983 and state law against Chicago, Macon, the arresting officers, and others. Chicago was dismissed before trial because municipalities are not vicariously liable under section 1983, and the district judge found that none of the city’s policies (including its training regimens) was constitutionally deficient. The jury rejected claims against the other defendants, but decided in Richardson’s favor on one claim, concerning the shot Macon fired, and awarded $1 in nominal damages plus $3,000 in punitive damages. Macon did not appeal, nor did Chicago, which under Illinois law must indemnify Macon for the $1 but not the punitive award. Pursuant to 42 U.S.C. 1988, Richardson sought more than $675,000 in fees. The district judge awarded $123,000, noting that the firm’s billing did not allow non‑compensable time to be separated out. The Seventh Circuit affirmed the award as “generous, considering Richardson’s recovery.” View "Richardson v. City of Chicago" on Justia Law