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Employment & Labor Law for Public Safety Agencies


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Attorneys' Fees, Sanctions, and Legal Defense Rights

     A female municipal court clerk sued for quid pro quo and hostile environment sexual harassment as well as retaliation. She sought $323,027.35 in damages. A jury found in her favor only on the hostile work environment claim, awarding only $5,000 in damages. The attorneys' fees were calculated by the court as $94,612.50, but the award of fees to her as a prevailing plaintiff under Title VII were then reduced to $25,000, or five times the amount of damages awarded. The trial court believed that it was constrained by prior case law to reduce the attorneys' fee award to less than 6.5 times the damage award. The federal appeals court aand damages may be considered in determining a reasonable fee, but prior cases did not impose "a per se proportionality requirement" of less than 6.5 times the amount of damages. A new calculation of the appropriate fee award was therefore ordered. Combs v. City of Huntington, #15-40436, 2016 U.S. App. Lexis 13049 (5th Cir.).
     A city sought to compel the city's employee retirement system to increase employee's contributions to their retirement fund to help pay for an $800 million investment loss the fund had suffered. Four public employee labor unions intervened in the case, echoing the arguments made by the retirement system as to why the city's request should be denied. The case was settled, with the city agreeing not to seek to make the employees pay for past unfunded accrued actuarial liabilities, and to meet and confer about any future changes. The unions sought to recover $1,785,147 in public interest attorneys' fees under a California state statute. An intermediate California appeals court upheld the denial of such a fee award when the unions failed to show that their intervention was necessary to the outcome of the case, or that the venue and discovery motions they filed had any significant impact on the litigation. San Diego Municipal Employees Assoc. v. City of San Diego, #D066886,244 Cal. App. 4th 906, 2016 Cal. App. Lexis 94.
     A former postal employee claimed that he faced discrimination and was ultimately terminated in violation of his rights under the Uniformed Services Employment and Reemployment Rights Act (USERRA) for taking military leave, which the employer regarded as excessive. He prevailed in two appeals on his discrimination claims to the Merit Systems Protection Board, and was awarded reinstatement with backpay and benefits. He was not entitled to attorneys' fees, however, as USERRA's attorneys' fee provision, 38 U.S.C. Sec. 4324(c)(4), did not authorize the Board to award attorneys' fees incurred during judicial review and there was no independent statutory provision for an award of attorneys' fees by a reviewing court. Erickson v. U.S. Postal Serv., #08-3216, 759 F.3d 1341 (Fed. Cir. 2014).
     Claims for wrongful termination and defamation filed by five former part-time and seasonal village police officers against the county defendants, who did not employ or supervise them, were frivolous from the beginning, requiring the county defendants to litigate continuously at taxpayer expense for years. Accordingly, the trial court's award of $63,990 in attorneys' fees and costs to the prevailing county defendants was within its discretion. Carter v. Incorporated Village of Ocean Beach, #13-815, 2014 U.S. App. Lexis 13865 (2nd Cir.).
     Even though a candidate for chief of police won his election, he sued his opponent for violation of his federal civil rights, as well as claims under state law, for allegedly interfering with his right to seek public office. A federal court dismissed the federal claims as frivolous, and sent the other claims to state court. The U.S. Supreme Court held that reasonable attorneys' fees could be awarded to the defendant under 42 U.S.C. Sec. 1988, but only for costs that the defendant would not have incurred "but for the frivolous claims." Fox v. Vice, #10-144, 2011 U.S. Lexis 4182.
     Federal Merit Board upholds an award of legal fees against the DoJ, arising over the successful defense of an officer charged with excessive force. A fee award is not improper simply because a percentage will be turned over to a union's litigation fund. Thompson v. Dept. of Justice, #CH-0752-08-0632-A-1, 2010 MSPB 244.
     Pennsylvania appellate court denies payment of legal defense costs of $107,385 and $178,156, sought by a former corporal and a former chemist who were sued for withholding exculpatory evidence in a murder investigation. The defendants purportedly acted maliciously and in bad faith, resulting in the 23-year imprisonment of the plaintiff. Balshy v. Penn. State Police, #99 C.D. 2009, 988 A.2d 81, 2010 Pa. Commw. Lexis 63.
     Supreme Court affirms a District Court award of attorney's fees to a disabled worker who initially was denied benefits under an employer-provided long-term disability insurance policy. Hardt v. Reliance Std. Life Insur. Co., #09-448, 2010 U.S. Lexis 4164.
    Police chief awarded attorney’s fees for defending a baseless lawsuit brought by a rival candidate for the police chief position. Fox v. Vice, #08-31135, 594 F.3d 423, 2010 U.S. App. Lexis 1171 (5th Cir.).
     Seventh Circuit upholds an award of attorney’s fees and costs to the county after finding that the plaintiff, a deputy sheriff, litigated part of his age discrimination lawsuit in bad faith. Mach v. Will Co. Sheriff, #08-2907, 2009 U.S. App. Lexis 19631, 107 FEP Cases (BNA) 13 (7th Cir.).
     Arbitrator awards attorneys’ fees to the union in a FLSA grievance, citing FLRA precedent. Fed. Bur. of Prisons and AFGE L-1006 (III), FMCS Case #07/04342, 126 LA (BNA) 832 (Nicholas, 2009).
     If an administrative judge decides not to award fees for hours of attorney service that are adequately documented, he/she must identify those hours and give a clear explanation for their elimination. “An appellant is entitled to recover attorney fees for time spent preparing a motion for attorney fees.” Wightman v. Dept. of Veterans Affairs, Docket #DE-0752-07-0485-A-1, 2009 MSPB 55, 2009 MSPB Lexis 1845.
     Sixth Circuit affirms a judgment of $660,103 in legal fees and expenses assessed against African-American court employees and their attorney "for maintaining frivolous discrimination claims long after those claims had clearly become groundless." 93.8% of African-American employees received a position upgrade, while only 70.1% of Caucasians did. "These statistics are hardly supportive of the appellants’ disparate-impact claims." Garner v. Cuyahoga Co. Juvenile Court, #07-3602, 2009 U.S. App. Lexis 1289 (6th Cir.).
     California appeals panel rejects preliminary injunctive relief because a sheriff's dept. revised its procedures to prevent officers, who were either involved in or witnessed an officer-involved shooting, from consulting with legal counsel and or labor representatives collectively or in groups (two or more officers consulting at the same time with the same legal counsel/labor representative). They may continue to consult counsel individually, or to be represented as a group at a later time. Nothing in the constitution or bargaining laws warrants an injunction against the policy change while the litigation is pending. Assn. L.A. Deputy Sheriffs v. Co. of Los Angeles, #B197611, 2008 Cal. App. Lexis 1460 (2nd Dist.).
     Federal Merit Board affirms a decision to award an air marshal the legal costs of overturning his termination, but reduces the amount from $99,322 to $72,302. Coradeschi v. Dept. of Homeland Security, #NY-0752-04-0163-A-1, 2008 MSPB 199.
     A party suing the federal government may recover paralegal fees from the government at the prevailing market rates under the Equal Access to Justice Act, and is not limited to the cost to the party's attorney. Richlin Security. v. Chertoff, #06-1717, 2008 U.S. Lexis 4522.
     After a county police dept. refused to allow light duty status for pregnant officers, a jury awarded damages to five women plaintiffs. The court also awarded plaintiffs $578,704 for attorneys' fees and costs, noting that "the plaintiffs did not justify the need to retain sixteen attorneys and thirteen support staff from five different firms/agencies to represent six plaintiffs with essentially the same claims" thus reducing the number of overall hours by 25%. Lochren v. Co. of Suffolk, #CV-01-3925, 2008 U.S. Dist. Lexis 38100 (E.D.N.Y.).
     Federal court orders a sanction of $24,407 against a police officer and his counsel for violating a protective order concerning a parody police video, which allegedly contained racist, sexist, and homophobic scenes, after they disclosed confidential excerpts from a video deposition to the news media. Harmston v. City of San Francisco, #07-cv-01186, 2007 U.S. Dist. Lexis 74891, 102 FEP Cases (BNA) 402 (N.D. Cal.)
     Appellate court sustains most of an attorney fee award of $1.1 million for a recovery of $30,300 in a discrimination action brought by an airport safety officer. "The law does not mandate, however, that attorney fees bear a percentage relationship to the ultimate recovery of damages in a civil rights case." Harman v. C&C of San Francisco, #A115519, 2007 Cal. App. Lexis 2079 (1st Dist.).
     Ninth Circuit affirms dismissal of a retaliation suit filed by a sheriff's deputy that was fired for sexual harassment. Court also sustains an award of attorney's fees to the county against the ex-deputy, who alleged disability and national origin discrimination. Loera v. Co. of Imperial, #06-55438, 2007 U.S. App. Lexis 27781 (Unpub. 9th Cir.).
    Pennsylvania appellate court vacates part of an impasse award requiring the Corrections Dept. to provide legal representation to state corrections employees in any legal proceeding arising from employment-related conduct, even if that conduct was criminal and malicious, and to indemnify them against civil judgments resulting from such conduct. It violated Pennsylvania Code. Dept. of Corrections v. Corrections Officers Assn., #445 C.D. 2006, 932 A.2d 359, 2007 Pa. Commw. 515.
     California appellate court affirms a holding that a city is obligated to pay the legal fees and expenses of the members of a municipal retirement board. Torres v. City of San Diego, #D049111, 2007 Cal. App. Lexis 1356 (4th Dist.).
     Second Circuit overturns an arbitration award that denied a prevailing age discrimination plaintiff the recovery of $262,000 in attorney fees. Porzig v. Dresdner Kleinwort, #06-1212-cv, 2007 U.S. App. Lexis 18674 (2nd Cir.).
     Federal appeals court holds that plaintiffs were entitled to an award of attorneys fees in a lawsuit that challenged the employer's use of a psychological test as a condition of promotion purposes; an injunction ordering the destruction of the test results conferred enough of a benefit on the plaintiffs to classify them within the ADA's definition of a prevailing party. Karraker v. Rent-A-Center, #06-2617, 2007 U.S. App. Lexis 16184 (7th Cir.).
     When a consent decree establishes mechanisms for ensuring proper treatment of class members, additional attorney fees should be awarded for reasonable efforts to ensure that those mechanisms are properly functioning. Johnson v. City of Tulsa, #5-5064, 2007 U.S. App. Lexis 13915 (10th Cir. 2007).
     Federal court approves an award of attorneys' fees of $642,874 in a Title VII gender discrimination case. The case was fiercely litigated, and the city contested every move the officers made. The plaintiff ultimately recovered $325,000 in damages. O'Sullivan v. City of Chicago, #01Cv9856, 2007 U.S. Dist. Lexis 18421 (N.D. Ill.).
     Under the Equal Access to Justice Act, paralegal costs are not recoverable as fees, but are only recoverable when they are itemized expenses of a successful attorney. Richlin v. Chertoff, #06-1055, 2006 U.S. App. Lexis 31749 (Fed Cir. 2006). [N/R]
     Idaho Supreme Court rules that the state's Personnel Commission lacked the authority to award attorneys' fees and pre-judgment interest to a former corrections officer that had been terminated without proper cause. Sanchez v. Idaho Dept. of Corr., #32266, 141 P.3d 1108, 2006 Ida. Lexis 114 (2006). {N/R}
     Ninth Circuit affirms a sanction of dismissal of the plaintiff's lawsuit and the imposition of $65,000 in legal fees for erasing 2,200 files from a laptop computer during the pendency of sexual harassment litigation. Leon v. IDX Systems, #04-35983, 464 F.3d 951, 2006 U.S. App. Lexis 23820 (9th Cir. 2006). {N/R}
     Tenth Circuit holds that when a litigant enters into a private settlement, without any judicial involvement, he is not a prevailing party, and is entitled only to an award of reduced attorney's fees. The Supreme Court held in Buckhannon Board v. West Virginia HHS, 532 U.S. 598 (2001) that a person is a "prevailing party for the purpose of awarding attorneys' fees under §1988 only if he has obtained a judgment on the merits, a consent decree, or some other settlement materially altering the legal relationship of the parties. Bell v. Jefferson Co. Cmsnrs., #05-3224, 2006 U.S. App. Lexis 15157 (10th Cir. 2006). {N/R}
     The Civil Service Reform Act grants a "prevailing party," not the attorney, a legally protected interest in claiming attorney's fees. The lawyer lacks standing to appeal an award for fees that is less than requested. Willis v. Govt. Accountability Office, #05-6003, 2006 U.S. App. Lexis 12082 (Fed Cir. 2006).{N/R}
     Transsexual police officer, who won a jury verdict on her sex discrimination claim, recovers a supplemental award of attorneys' fees of $90,344 plus expenses of $2,540 for successfully defending the appeal before Sixth Circuit and U.S. Supreme Court. A lodestar multiplier of 1.75 that was applied to the trial-related legal fees should not apply to the appellate work. Barnes v. City of Cincinnati, #1:00-cv-780, 2006 U.S. Dist. Lexis 8826, 97 FEP Cases (BNA) 1168 (S.D. Ohio 2006). {N/R}
     In a termination suit where the employee was fired for an unlawful reason, the jury can refuse to award damages if there is proof the plaintiff would have been discharged for a valid reason. The 8th Circuit also affirmed a denial of attorney's fees because the plaintiff was not a prevailing party. Garner v. Missouri, #04-3013, 439 F.3d 958, 2006 U.S. App. Lexis 6037 (8th Cir. 2006). {N/R}
     Seventh Circuit upholds an award to a union, assessed against the employer, for filing a lawsuit to overturn an arbitration award. Cuna Mutual Insur. v. Office & Prof. Employees L-39, #05-1021, 2006 U.S. App. Lexis 6390 (7th Cir. 2006). {N/R}
     The Merit Systems Protection Board has discretion whether to award an employee a reasonable attorney fee and other litigation expenses in a case involving military leave time. Jacobsen v. Dept. of Justice, #DC-3443-05-0092-A-1, 2005 MSPB Lexis 5022(MSPB 2006). {N/R}
     Federal court awards $995,781 in legal fees and $26,873 in costs to counsel for an employer that was sued by the EEOC without just cause. EEOC v. Robert L Reeves & Assoc., #2:00-cv-10515, 2006 U.S. Dist. Lexis 4395 (C.D. Cal. 2006) -- Order Granting Fees [Doc. 676]. {N/R}
     Arbitrator allows a successful grievant to recover attorney's fees noting that when one party acts arbitrarily, capriciously, or in bad faith, such fees awards have been upheld by the courts. City of Mansfield and IAFF L-266, 121 LA (BNA) 1141, FMCS Case No. 0555999-8 (Szuter, 2005). [2006 FP Feb]
     Missouri Supreme Court concludes that the Metropolitan Police Dept. of the City of St. Louis is a state agency, that the attorney general has a duty to defend all lawsuits and that the state is obliged to pay all judgments. Smith v. State of Missouri, #SC86050, 152 S.W.3d 281, 2005 Mo. Lexis 5 (2005). {N/R}
     Lawyers for a transsexual police officer that won a suit for sex discrimination and retaliation are awarded $553,726 in fees and costs by a federal judge who rejected the city's arguments that a 1.75 multiplier, to recognize the "novelty and difficulty" of the case, was excessive. Last year the plaintiff was awarded $320,511 in damages. An appeals bond in the amount of $873,726 will be required, and the court declined to stay its injunction. Barnes v. Cincinnati, #C-1-00-780, 42 (2050) G.E.R.R. (BNA) 257 (S.D. Ohio 2004). {N/R}
     New York's highest court agrees with a decision not to indemnify or defend an off-duty police officer that had his neighbor arrested for zoning violations. Salino v. Cimino, #128, 1 N.Y.3d 166, 802 N.E.2d 1100, 2003 N.Y. Lexis 4100 (2003). [2004 FP Apr]
     Federal appeals court allows only $85,000 in legal fees and costs, of the $3.5 million sought by ex-president Clinton and his wife. The seven-year Whitewater investigation cost the government $70 million. In re Madison Guaranty S&L (Clinton Fee Application), No. 94-1, 2003 U.S. App. Lexis 14170 (D.C. Cir. 2003). {N/R}
     The New Jersey Supreme Court has ruled that public officials may not terminate a lawyer who serves a fixed term or who cannot be removed except for cause. Coyle v. Board of Chosen Freeholders of Warren County, #A-110 Sept. Term 2000, 170 N.J. 260, 787 A.2d 881, 2002 N.J. Lexis 1 (2002). [2002 FP Apr]
     A self-insured governmental entity is not an "insurer," and its agreement to indemnify employees for claims arising in the course and scope of their employment is not insurance; thus, such an entity is not bound by a state insurance requirement that the insured's consent be obtained before settling a lawsuit against the insured. Chambi v. Regents of the Univ. of Cal., #G024554, 95 Cal. App. 4th 822, 116 Cal. Rptr. 2d 50, 2002 Cal. App. Lexis 288 (Cal.App. 4th Dist. 2002). [N/R]
     Federal appeals court affirms an award of attorneys fees of $277,900 given to a woman fire dept. employee who had sued for disparate treatment. In an earlier ruling the court upheld compensatory damages of $47,100. Kline v. City of Kansas City Fire Dept., 1981A/1208, 245 F.3d 707, 2001 U.S. App. Lexis 10972 (8th Cir.); prior opin. at 175 F.3d 660, 1999 U.S. App. Lexis 8500; cert den., 2000 U.S. Lexis 1040. {N/R}
     California Supreme Court allows plaintiff's counsel to collect the larger of a pre-agreed contingency fee or the statutory fees awarded by the court. Flannery v. Prentice, #S080150, 26 Cal.4th 572, 28 P.3d 860, 2001 Cal. Lexis 5256, 01 C.D.O.S. 6991. {N/R}
     Arbitrator holds that the city violated the bargaining agreement when it refused to pay the attorney's fees of the police chief for defending a meritless lawsuit, where no disciplinary action was taken against the chief, and the city settled the court action while continuing to deny liability. City of Morton and Teamster's L-252, WA-PERC #15086-A-00-1347, 115 LA 444 (Schwendiman, 2001). {N/R}
     Supreme Court, in a 5-4 holding, rejects "catalyst theory" for awarding attorneys' fees in civil rights cases. Buckhannon Bd. & Care Home v. W.Va. Dept. of H.H.R., #99-1848, 532 U.S. 598, 121 S.Ct. 1835, 2001 U.S. Lexis 4117, 69 L.W. 4350 (5/29/01). {N/R}
     N.Y. Court denies attorney's fees to an officer accused of misconduct, because he failed to pursue his claim under procedures embodied in the PBA bargaining agreement. Dobrin v. PBA of NYC, QDS: 22702603 (Sup.Ct. N.Y. Co. 2000). [2000 FP 116]
     An award of attorney fees to the union to enforce an arbitration award violated the general rule that a prevailing party may not recover attorney fees as costs of litigation in the absence of statutory authority, unless provided for in the bargaining agreement. The panel said that attorneys' fees would be appropriate only as a sanction when an employer's position was legally unjustifiable, unreasonable, or frivolous. Leis v. L-100 Teamsters, #C-981011, 1999 Ohio App. Lexis 4982, 162 LRRM (BNA) 3084. [2000 FP 42]
     Fourth Circuit holds that employees who win a Title VII discrimination claim in an administrative setting cannot bring a lawsuit in federal court solely to recover their attorneys' fees. Chris v. Tenet, #99-2140, 221 F.3d 648, 2000 U.S. App. Lexis 18093, 83 FEP Cases (BNA) 724 (4th Cir. 2000). The panel disregarded a prior decision from the 8th Circuit, Jones v. Amer. St. Bk., 857 F.2d 494 (8th Cir. 1988). {N/R}
     Wisconsin’s Employment Relations Cmsn. holds that a firefighter's local union had no duty to provide a member of the bargaining unit with an attorney for a disciplinary hearing before the city's Board of Police and Fire Cmsnrs.. Hopkins v. City of Kenosha, WERC #29715-C (2000). Text: www.wisbar.org/werc/cd/2000/29715-a.htm {N/R}
     N.J. police officer was not entitled to recovery his legal fees after winning a disciplinary hearing. Oches v. Twp. of Middletown Police, #A-86/87, 155 N.J. 1, 713 A.2d 993, 1998 N.J. Lexis 570. {N/R}
     Officer who was entitled to be represented in a civil rights suit where he was the defendant, could be required to select from one of three attorneys on a list provided to him by the city's Corporation Counsel. Mothersell v. City of Syracuse, 952 F.Supp. 1112 (N.D.N.Y. 1997). {N/R}
     Costs of computerized legal research are includable in a recovery where attorney's fees are allowed. Matter of Luq. Azstar Cas. Co., 1996 WL 523535 - unpublished opin. (Ariz. App.) {N/R}
     Federal court declines to overturn an arbitrator's decision not to award attorney's fees to a grievant that prevailed in an age discrimination complaint that went to arbitration, even though the award was mandated by the ADEA. The plaintiff's attorney had failed to inform the arbitrator that the award was required by federal law. Russa v. D.W.R., 71 FEP Cases (BNA) 937 (S.D.N.Y. 1996). {N/R}
     Dept. head was not entitled to be paid his attorneys fees for a lawsuit he brought in a budget dispute. Simon v. Bd. of Freeholders, 281 N.J.Super. 417, 658 A.2d 306 (A.D. 1995). [1996 FP 19]
     Federal appeals court strikes down a collective bargaining provision that awarded attorneys" fees to the prevailing party. Moore v. Local 569 IBEW, 1995 U.S.App. Lexis 10088 (9th Cir.). [1995 FP 116-7]
     Police Federation of England & Wales reports that nearly 1 in 10 officers are pursuing legal actions or receiving legal advice paid by a federation administered legal support plan. Daily Telegram (U.K.) Nr. 43,518, p. A-2 (May 22, 1995). {N/R}
     Federal court awards police chief and city $22,258 in legal fees and costs against an ex-officer who filed a frivolous lawsuit challenging his termination. Kennedy v. McCarty, 803 F.Supp. 1470 (S.D.Ind. 1992). [1993 FP 100]
     Employees who win administrative disputes because of civil rights reasons cannot recover their attorney's fees in a separate suit. North Carolina Department of Transportation v. Crest St. Commun. Council, 107 S.Ct. 336 (1986).
     White employees who unsuccessfully intervened in race discrimination suit not required to pay opposing party's legal fees. Paradise v. Prescott, 626 F.Supp. 117 (M.D. Ala. 1985).
     Supreme Court allows civil rights plaintiffs to recover huge attorneys" fees in modest cases; no proportionality required. City of Riverside v. Rivera, 106 S.Ct. 2686 (1986).
     Police Chief awarded attorney's fees against subordinate who sued him for proper disciplinary action. Hershinow v. Bonamarte, 772 F.2d 394 (7th Cir. 1985).
     Federal appeals court awards chief attorney's fees and costs, against transferred officer and attorney who took frivolous appeal. Hughes v. Hoffman, 750 F.2d 53 (8th Cir. 1984).
     Federal appeals court upholds fees award in injunctive action even though plaintiff was unsuccessful in reinstatement claim. Burney v. City of Pawtucket, 728 F.2d 547 (1st Cir. 1984).
     Legal aid lawyers entitled to prevailing rates in private practice, civil rights cases do not justify "bonus" factor for novelty or complexity. Blum v. Stenson, 104 S.Ct. 1541 (1984).
     Federal appeals court holds government attorneys could not represent employee and employer in same suit; conflict of interests between departments and its employees cited. Dunton v. County of Suffolk, 729 F.2d 903 (2nd Cir. 1984).
     Officer not entitled to legal costs where misconduct upheld, but punishment reduced on appeal. McLean v. Town of Natick, 437 N.E.2d 570 (Mass. App. 1982).
     Sex discrimination victim entitled to counsel fees for collateral state proceedings. Kingsley v. New York Dept. of Correctional Services, 30 FEP Cases (BNA) 121 (W.D.N.Y. 1982).
     Fire dept. paramedic who settled claims with chief entitled to legal fees of $45,552 including 150 percent multiplier. Strama v. Peterson, 541 F.Supp. 75 (N.D. Ill. 1982).
     Fire and police chiefs entitled to recover legal costs in their suit for reinstatement, under general indemnity law. Anderson v. City of Kewanee, 425 N.E.2d 593 (Ill.App. 1981).
     Reinstated chief entitled to recover attorney's fees in successful state court action under "public trust doctrine'. Foster v. Town of Hudson, 441 A.2d 1183 (N.H. 1982).
     Settlements of civil rights actions are not final unless they contain provisions for legal fees. Chicano Police Officer's Assn. v. Stover, 624 F.2d 127 (10th Cir. 1980); Bolden v. Penn. State Police, 491 F.Supp. 958 (E.D. Pa. 1980).
     Officer entitled to recover legal fees for representation in grand jury investigation of officer for off-duty shooting. Van Horn v. City of Trenton, 80 N.J. 528, 404 A.2d 615 (1979).
     New Jersey Court outlines circumstances when public employees can receive attorney's fees; effect of statutes and collectively bargained agreements. Twp. of Waterford v. Babli, 158 N.J. Super. 569, 386 A.2d 906 (A.D. 1978).
     See also: Damages; Sex Discrimination.

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