Singhaviroj v. Board of Education, 301 Conn. 1

In 2004, Singhaviroj was terminated from his municipal board information technology role for disruptions in the board's computer network.
In 2005, Singhaviroj sued the town and board under 42 U.S.C. § 1983 alleging due process and equal protection violations, plus a § 7-465 indemnification claim.
The defendants moved to strike the complaint, arguing lack of required property interest or protected liberty interest and lack of a class-of-one predicate.
After initial rulings striking the complaint for failure to state a claim, Singhaviroj filed four amended complaints reasserting substantially identical claims.
The trial court struck each amended complaint; Judge Gilardi later granted a fifth motion to strike after finding no legally sufficient due process or equal protection claims.
The defendants sought attorney’s fees under § 1988(b); Singhaviroj argued the American Rule and bad faith were required; the court awarded $3,000, which the appellate court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1988(b) awards require bad faith.	Singhaviroj contends no bad faith is needed; improper to confer fees merely for frivolous claims.	Defendants contend § 1988(b) allows fees where claims are frivolous or litigated after groundlessness, not requiring subjective bad faith.	Fee award upheld under the frivolous/groundless standard; no bad faith required.
Whether the court properly found the claims frivolous as to due process and stigma-plus.	Plaintiff argues stigma-plus and property interests supported his claims; not frivolous.	Defendants contend the amended complaints failed to state a stigma-plus due process or class-of-one claim.	Court held the claims were groundless; award appropriate.
Whether Singhaviroj persisted with groundless claims after they became evident.	Plaintiff asserts continued litigation was in good faith to shore up potentially viable claims.	Defendants show five identical complaints and continued litigation after repeated strikes.	Court found persistence after groundlessness supported fee award.
Whether the amount of fees awarded was appropriate.	Plaintiff did not contest the fee amount; challenged the basis for award.	Fees were necessary to deter frivolous repleading; amount modest in context.	Affirmed the fee award as reasonable and within discretion.

Hughes v. Rowe, 449 U.S. 5 (U.S. Supreme Court, 1980) (strict standard for fees against prevailing defendants under § 1988(b))
Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (U.S. Supreme Court, 1978) (fe e shifting standards for prevailing defendants; frivolous or groundless claims)
DeBauche v. Trani, 189 F.3d 499 (4th Cir. 1999) (sanctions against baseless civil rights claims)
Hutchinson v. Staton, 994 F.2d 1076 (4th Cir. 1993) (district court may award § 1988(b) fees where claim was groundless)
Mikes v. Straus, 274 F.3d 687 (2d Cir. 2001) (subjective bad faith not required for § 1988(b) fees)
Segal v. City of New York, 459 F.3d 207 (2d Cir. 2006) (stigma-plus third element and pretermination process discussed)
Neilson v. D'Angelis, 409 F.3d 100 (2d Cir. 2005) (class-of-one standard requires near-identical circumstances)