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p0013 REVIEW DENIED A trial court has discretion to deny attorney fees to plaintiffs who have limited success in an action under the federal Civil Rights Act, but even limited success establishes that the action was not frivolous, so the trial court has no discretion to award fees to defendants against whom no judgment was rendered.CitationCHOATE v COUNTY OF ORANGE (Street Justice) 86 CA4 312 [See: 42 USC 1983; Mcfetters v Amplicon (Depub) 82 CA4 200, T/AT 9/00; Farrar v Hobby 506 US 103; Hughes v Rowe 449 US 5]
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