Business which settled $19 million harassment claim for $16,000 was prevailing party entitled to attorneys' fees when settlement agreement did not mention such fees. Stefan v. Laurenitis, 889 F.2d 363 (1st Cir. 1989).
     Civil rights plaintiff who merely succeeded in having arrest record expunged was not prevailing party; no attorneys' fee award. Ortega v. City of Kansas City, Kan, 723 F.Supp. 1426 (D.Kan 1989).
     Prevailing plaintiffs may sue for attorneys' fees unless settlement "clearly waived" fees. Muckleshoot Tribe v. Puget Sound Power & Light, 875 F.2d 695 (9th Cir. 1989).
     Award of attorneys' fee may be increased because of delay in payment; payment for paralegal and law clerk work may be awarded Missouri v. Jenkins, 109 S.Ct. 2463 (1989). Prevailing plaintiff's fee request not reduced because he succeeded on only some of claims when all claims were interrelated. Lawrence v. City of Philadelphia, 700 F.Supp. 832 (E.D. Pa. 1988).
     Successful civil rights plaintiff entitled to certain costs in addition to attorneys' fees Allen v. Freeman, 122 F.R.D. 589 (S.D.Fla 1988).
     Attorney's contingent fee agreement with plaintiff does not limit the amount of attorneys' fees to be awarded in a civil rights case. Blanchard v. Bergeron, 57 U.S.L.W. 4191 (1989).