96 Wash. App. 773 - Steele v. Lundgren’s Empirical Analysis
1999
Citation profile
19 state decisions
How this case has been cited
Cited by 21 later decisions — most recently February 2021
19 state decisions
Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.
Relationships
Applies 42 U.S.C. § 1988 · 42 U.S.C. § 3601 (§ 801 of the Fair Housing Act (Title VIII, Civil Rights Act of 1968))
Relies on Hensley v. Eckerhart · City of Riverside v. Rivera · 100 Wash. 2d 581 - Bowers v. Transamerica Title Insurance · Mahler v. Szucs · 108 Wash. 2d 558 - Blair v. Washington State University
Most-quoted passages
The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 21 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.
“In some cases a plaintiff may present in one lawsuit distinctly different claims for relief that are based on different facts and legal theories. In such a suit ... counsel’s work on one claim will be unrelated to his work on another claim.... [Statutes limiting recovery of attorney’s fees] to prevailing parties require[ ] that these unrelated claims be treated as if they had been raised in separate lawsuits, and therefore no fee may be awarded for services on the unsuccessful claim[s]. In other cases the plaintiffs claims for relief will involve a common core of facts or will be based on related legal theories. Much of counsel’s time will be devoted generally to the litigation as a whole, making it difficult to divide the hours expended on a claim-by-claim basis. Such a lawsuit cannot be viewed as a series of discrete claims. Instead the district court should focus on the significance of the overall relief obtained by the plaintiff in relation to the hours reasonably expended on the litigation.”
1 later decision quote this exact passage · from the majority“Any person deeming himself or herself injured by any act in violation of this chapter shall have a civil action in a court of competent jurisdiction to enjoin further violations, or to recover the actual damages sustained by the person, or both, together with the cost of suit including reasonable attorneys' fees or any other appropriate remedy authorized by this chapter or the United States Civil Rights Act of 1964 as amended, or the Federal Fair Housing Amendments Act of 1988 ( 42 U.S.C. Sec. 3601 et seq.).”
1 later decision quote this exact passage · from the majority“Because damages awards do not reflect fully the public benefit advanced by civil rights litigation, Congress did not intend for fees in civil rights cases, unlike most private law cases, to depend on obtaining substantial monetary relief.”
1 later decision quote this exact passage · from the majority
How this case has been treated — in progress
Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.