HRT Enterprises v. City of Detroit, Mich
- Summarized by Jonathan Batiste , Rensselaer Polytechnic Institute
- 1 month 2 weeks ago
- Case Type:
- Business
- Case Status:
- Reversed and Remanded
- Citation:
- Nos. 24-1068/1116 (6th Circuit, Dec 22,2025) Published
- Tag(s):
-
- Ruling:
- Federal courts can award attorney’s fees for state-court proceedings that the law requires to advance federal claims. Caselaw has established a “separate-but-related proceeding” exception to fee recovery law. Despite that, Section 1988(c) expert witness fee shifting does not apply to actions or proceedings to enforce provisions of Section 1983. The expert-fee shifting only applies when enforcing provisions of Section 1981 and 1981a. The district court erred by awarding expert witness fees and by disallowing attorney's fees awards for those separate-but-related proceedings.
- Procedural context:
- HRT Enterprises sued the City of Detroit in state court for a takings claim in 2005, but a jury found in the City’s favor. HRT then sued in federal court in 2008, but the district court dismissed that suit because federal law required HRT to exhaust state-law remedies before commencing a federal action. HRT then returned to the state court system, which then dismissed HRT's action. HRT then returned to federal court in 2012, but the City filed for bankruptcy in 2013. But the bankruptcy court excepted HRT’s claim from discharge, and HRT returned to the district court to pursue full compensation. The district court later ruled in HRT’s favor, and HRT then moved for attorney’s fees. After the district court determined HRT’s award, both the City and HRT appealed to the circuit court.
- Facts:
- HRT filed a $7 million proof of claim in Detroit’s bankruptcy after suing the City for a takings claim. After the district court found in favor of HRT, HRT also moved for almost $2 million in attorney’s fees. The district court expressed doubts about the fees that HRT requested because HRT had poor record-keeping practices. Thus, after doing some calculations, the court awarded HRT less than $1 million. That amount included an award for expert witness fees. The district court erred by awarding those expert witness fees and by disallowing attorney’s fees related to HRT’s state-court proceedings.
- Judge(s):
- Griffin, Thapar, Mathis
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