can you help me clean this up and sound better, but don't add fluff, it is going to be a legal memo: Analysis:

Issue 1: if a plaintiff in an ADA case was awarded nominal damages of $1, a declaratory judgment, and injunctive relief, would they be considered a prevailing party (entitling them to attorney’s fees). 

Takeaway: Yes. In most cases I have come across in the 2nd Circuit where plaintiffs were awarded nominal damages and an injunction, the injunction was deemed substantial enough to justify attorney's fees. Further, the presence of a declaratory judgement likely solidifies granting attorney’s fees.

Analysis: Prevailing party? 

Plaintiff is prevailing party if:
(1)	success on issues achieves some of benefit sought, and 
a.	satisfied (lay out what benefit was sought and what was ultimately given)
(2)	changes relationship between plaintiff and defendant 
a.	satisfied (check the terms of the injunction/ declaratory judgment to see how the relationship b/w parties changed before and after its implementation)


(1) Rule Statement: "[P]laintiffs may be considered 'prevailing parties' for attorney's fees purposes if they succeed on any significant issue in litigation which achieves some of the benefit the parties sought in bringing suit." (quoting Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S. Ct. 1933, 76 L. Ed. 2d 40 (1933) )

[Robles v. City of New York, United States District Court for the Southern District of New York, Feb 26, 2021, 2021 U.S. Dist. LEXIS 39126]

(1) Applied: 


(2) Rule Statement: 

Further, a plaintiff prevails when actual relief on the merits of his claim materially alters the legal relationship between the parties by modifying a defendant's behavior in a way that directly benefits the plaintiff. An injunction or declaratory judgment, like a damages award, will usually satisfy that test.

Lefemine v. Wideman, 568 U.S. 1, 4 (2012)

A civil rights plaintiff who obtains a permanent injunction qualifies as a prevailing party presumptively entitled to attorney’s fees if the injunction orders the defendant to change its behavior in a way that benefits the plaintiff, even if the plaintiff’s request for monetary damages is denied [Lefemine v. Wideman, 568 U.S. 1, 133 S. Ct. 9, 184 L. Ed. 2d 313, 315–316 (2012)].

Applied: 

In Integrity Communications Corp. v. Baker, the court recommended granting nominal damages and a permanent injunction, which constituted a material alteration of the legal relationship between the parties, thus making the plaintiff a prevailing party. Integrity Communs. Corp. v. Baker, 2013 U.S. Dist. LEXIS 130100. “Integrity is entitled to a permanent injunction against Baker for copyright infringement….Integrity is entitled to reduced attorney's fees and costs totaling $20,000 as the prevailing party.”

Farrar v. Hobby, the Supreme Court held that a plaintiff who wins nominal damages is a prevailing party because the judgment alters the legal relationship between the parties by forcing the defendant to pay an amount of money they otherwise would not pay. Aptive Env't, LLC v. Vill. of E. Rockaway, 2022 U.S. Dist. LEXIS 171785, Integrity Communs. Corp. v. Baker, 2013 U.S. Dist. LEXIS 130100.

Aptive Env't, LLC v. Vill. of E. Rockaway, 2022 U.S. Dist. LEXIS 171785- The permanent injunction prohibited the village from enforcing an unconstitutional ordinance, thus altering the legal relationship between the parties and conferring prevailing party status on Plaintiff under § 1988… Key Legal Holding: Plaintiff is a "prevailing party" eligible for attorneys' fees under 42 U.S.C. § 1988 because the permanent injunction materially altered the legal relationship between the parties.