In the 

United States Court of Appeals 

For the Seventh Circuit ____________________ 

No. 20-3492 

LYDIA E. VEGA, 

Plaintiff-Appellee, 

v.

CHICAGO PARK DISTRICT, 

Defendant-Appellant. 

____________________ 

Appeal from the United States District Court for the 

Northern District of Illinois, Eastern Division. 

No. 1:13-cv-00451 — Jorge L. Alonso, Judge. 

____________________ 

ARGUED MAY 27, 2021 — DECIDED SEPTEMBER 1, 2021 

____________________ 

Before KANNE, SCUDDER, and KIRSCH, Circuit Judges. 

KIRSCH, Circuit Judge. Title VII of the Civil Rights Act of 

1964 is one of several federal statutes that allows a prevailing 

party to shift its attorneys’ fees to its adversary. After years of 

litigation, a federal jury sided with Lydia Vega on her national 

origin discrimination claim against the Chicago Park District. 

We affirmed that result on appeal. The parties then began discussing Vega’s attorneys’ fees request. But, just as in the merits litigation, the parties could not resolve their differences. 
2 No. 20-3492 

Vega ultimately submitted two fee petitions to the district 

court—covering two distinct time periods—that the court 

granted. The district court also granted Vega’s request for a 

tax-component award to offset her income tax liability on the 

backpay award from her successful Title VII claim. The Park 

District now appeals, taking aim at both the reasonableness of 

the attorneys’ fee awards and the amount of the tax-component award. For the reasons discussed below, we affirm. 

I 

In 2013, Lydia Vega, a Hispanic woman, brought 12 claims 

against the Chicago Park District all related to its investigation 

and termination of her employment for allegedly falsifying 

her timesheets. After extended pretrial motions practice, the 

district court allowed Vega’s national origin discrimination 

and retaliation claims under 42 U.S.C. § 1983 and Title VII to 

proceed to trial. 

The jury returned a verdict for Vega on the discrimination 

claims, but not the retaliation claims, and awarded $750,000 

in damages. The Park District moved for remittitur and for 

judgment as a matter of law on the discrimination claims; the 

district judge granted the former, reducing the award to Title 

VII’s statutory maximum of $300,000, and partially granted 

the latter, entering judgment for the Park District on Vega’s 

§ 1983 discrimination claim. After the district court held an 

equitable damages hearing, it ordered the Park District to reinstate Vega in her position, pay her backpay, provide her 

with the cash value of lost benefits, pay prejudgment interest, 

and pay a tax-component award (that is, an award granted to 

make a plaintiff whole by easing the tax burden from a lumpsum award). 
No. 20-3492 3

The Park District appealed every decision it lost at trial, 

and Vega cross-appealed the district court’s ruling on her 

§ 1983 discrimination claim. We affirmed all the district 

court’s rulings except for the tax-component award, which we 

held was not explained sufficiently for meaningful appellate 

review. The facts are set forth fully in our previous opinion. 

See Vega v. Chicago Park Dist., 954 F.3d 996, 1002–03 (7th Cir. 

2020). 

Not part of that first appeal was the issue of attorneys’ fees. 

On March 28, 2019, Vega submitted her first fee petition totaling $1,073,901.25. With her motion Vega included a 200-page 

document listing the date on which the work occurred, the 

billing attorney, a brief description of the work performed, the 

hours expended, and the total cost of the work. Vega redacted 

portions of the entries that she maintained were privileged or 

revealed litigation strategy. Vega’s counsel, Catherine Simmons-Gill,1 submitted sample contingent-fee agreements 

from 2018 and 2019, an hourly fee agreement, two agreements 

from her work as an expert witness, and three declarations 

from Chicago employment lawyers to support her current 

hourly rate of $425 for general tasks and $450 for in-court 

work. And she included declarations from three employment 

law practitioners attesting that the time she spent on this case, 

considering all circumstances, was reasonable. 

The Park District objected to all but $41,784.88 of Vega’s 

fee petition. It also insisted that the court should apply Simmons-Gill’s hourly rate at the time the litigation began of $300 

1 When we refer to Simmons-Gill, we are referring to all Vega’s many 

counsel. 
4 No. 20-3492 

per hour. The district court, in an order dated July 20, 2020,2

granted Vega’s first fee petition in the amount of $1,006,592. 

The court noted that the fees were “a massive amount for a 

single-plaintiff employment discrimination case” but laid 

some of the blame on the Park District for taking “a scorchedearth litigation approach” that “played a role in inflating the 

time [Vega’s] counsel spent on the case.” After noting that 

Vega voluntarily eliminated billing entries that exclusively 

concerned her unsuccessful claims, the district court held that 

Vega’s claims “were all bound up together in the same essential course of events consisting of the investigation of [Vega’s] 

timesheets and her ultimate termination.” Nonetheless, the 

district court reviewed Vega’s fee petition line by line (although under no obligation to do so). The court then disallowed line entries it found to be “plainly deficient” and reduced the total fee amount by 5% across the board.

The district court also held that using Simmons-Gill’s current billing rates was reasonable based on the three contingency representation agreements, affidavits from employment lawyers, an unexecuted hourly fee agreement, and Simmons-Gill’s expert witness agreements. The district court rejected the Park District’s request to apply Vega’s historical 

billable rates, reasoning that the Park District did not satisfy 

its burden under Pickett v. Sheridan Health Care Ctr., 664 F.3d 

632 (7th Cir. 2011), “to provide a good reason why a lower 

rate is essential” in this case, “particularly given that the delay 

in resolving this case can hardly be blamed on [Vega] or her 

counsel.” Noting that we have approved fee awards based on 

both current and historical billing rates, the court reasoned 

2 We refer to this order as the “July 20 order” to distinguish it from the 

district court’s order concerning Vega’s supplemental fee petition. 
No. 20-3492 5

that the “current-rate method has the virtue of simplicity” 

and was “more appropriate in a long-pending, multi-year 

case such as this one.” 

Vega filed a second fee petition totaling $254,635.69 for 

Simmons-Gill’s work following the first petition. The Park 

District objected to every entry except for $10,160. The district 

court disallowed Simmons-Gill’s fees for litigating a motion 

for clarification, for the cross-appeal of Vega’s § 1983 claim, 

and for hours her legal team spent conferring amongst themselves, ultimately awarding $218,221.69 in supplemental fees. 

In addition to attorneys’ fees, the district court also 

granted Vega a tax-component award of $49,224.30. The court 

based this award on redacted tax records Vega provided from 

2013 to 2019, showing no actual tax liability for each year from 

2013 to 2017 and $2,800 in tax liability for 2018; her testimony 

that, had she remained employed with the Park District from 

2012 to 2017, she would not have paid any federal income tax 

(based on her zero tax liability while employed with the Park 

District from 2010 to 2012); her testimony that she would have 

paid $2,800 in federal income tax in 2018 if employed with the 

Park District; and a calculation of the award, following the 

methodology described in Washington v. Office of the State Appellate Defender, No. 12 C 8533, 2016 WL 3058377 (N.D. Ill. May 

31, 2016). When employing the Washington methodology, the 

district court calculated Vega’s total income for the current tax 

year by adding together the backpay award and the compensatory damages award. It used this total to calculate Vega’s 

effective tax rate. The court then applied that effective tax rate 

to the backpay award (but not to the compensatory damages) 

to arrive at the tax-component award. In doing so, the court 

rejected the Park District’s argument that the compensatory 
6 No. 20-3492 

damages award should not be used to calculate Vega’s effective tax rate. 

II 

The Park District appeals the district court’s attorneys’ 

fees and tax-component awards. We address each in turn. 

A 

Section 2000e-5(k) of Title 42 permits a district court, in its 

discretion, to award reasonable attorneys’ fees to the prevailing party in a Title VII action. Pickett, 664 F.3d at 639. We review a district court’s determination of attorneys’ fees under 

a highly deferential abuse of discretion standard. Paz v. Portfolio Recovery Assocs., LLC, 924 F.3d 949, 954 (7th Cir. 2019). 

That level of deference follows from the nature of attorneys’ 

fees litigation. Specifically, we have observed that: “(1) [the 

district court] possesses superior understanding of the litigation and there exists a desirability of avoiding frequent appellate review of what essentially are factual matters; (2) the need 

for uniformity in attorneys’ fees awards is not great enough 

to warrant appellate review of minutia; and (3) the desirability of avoiding a second major litigation strictly over attorneys’ fees is high.” Farfaras v. Citizens Bank & Tr. of Chicago, 

433 F.3d 558, 569 (7th Cir. 2006) (internal citations and alteration omitted); see Fox v. Vice, 563 U.S. 826, 838 (2011). In practice, then, we find an abuse of discretion only “where no reasonable person could take the view espoused by the district 

court.” Cooney v. Casady, 735 F.3d 514, 518 (7th Cir. 2013) (quotation omitted). To the extent the appeal challenges the district court’s application of the “correct legal framework”, we 

review de novo. Nichols v. Ill. Dep’t of Transp., 4 F.4th 437, 441 

(7th Cir. 2021). 
No. 20-3492 7

1 

The Park District’s opening salvo takes broad aim at the 

district court’s approach to the burden of proving reasonable 

fees under Hensley v. Eckerhart, 461 U.S. 424 (1983). Neither 

party disputes that, under Hensley, Vega “bears the burden of 

establishing entitlement to an award and documenting the 

appropriate hours expended and hourly rates.” Id. at 437. But 

the Park District insists that the district court relieved Vega of 

that burden by acquiescing in Vega’s failure to “sufficiently 

document the tasks for which she [sought] fees[,]” instead requiring the Park District to “ferret out missing information.” 

In support, the Park District points to two aspects of the district court’s orders: (1) the district court’s “misgivings about 

the size of Vega’s legal bill” evidenced by several quotes from 

the July 20 order; and (2) the district court’s statement from 

the November 16 order, when addressing the Park District’s 

objections on vagueness grounds, that the Park District 

should have “ascertain[ed] during the meet-and-confer process what work [certain] entries ... pertained to, and, if appropriate, propose[d] a reduction on some reasonable basis other 

than intuition.” 

The Park District’s argument, however, misses the mark. 

The amount of the award in this case is no doubt very high, 

even for litigation that has been going on since 2013. But the 

district court’s analysis is not at odds with Hensley. The district court first evaluated Vega’s 200-plus-page spreadsheet 

line by line, striking dozens of entries that it found were 

plainly insufficient before reducing the total fee request by 

5%. Moreover, the district court found, “[f]or the most part,” 

Simmons-Gill’s “billing narratives contain a level of detail 

that paying clients would be likely to find acceptable.” Cf. 
8 No. 20-3492 

Spegon v. Catholic Bishop of Chicago, 175 F.3d 544, 552 (7th Cir. 

1999) (“[H]ours that an attorney would not properly bill to his 

or her client in the private sector cannot properly be billed to 

the adverse party under a fee-shifting statute.”). The misgivings the Park District identifies are neither in tension with the 

district court’s analysis nor a basis upon which to hold that it 

improperly shifted Vega’s burden. Furthermore, the district 

court’s analysis is consistent with what our cases require. We 

have held that “[o]nce a petitioning party provides evidence 

of the proposed fees’ reasonableness, the burden shifts to the 

other party to demonstrate the award’s unreasonableness.” 

Wachovia Secs., LLC v. Banco Panamericano, Inc., 674 F.3d 743, 

759 (7th Cir. 2012). So the district court’s statement in the November 16 order mentioned above accurately represents the 

back-and-forth of the parties’ burdens in attorneys’ fee litigation. 

2 

The Park District next broadly contends that the district 

court improperly awarded Vega fees for unsuccessful claims. 

When a plaintiff prevails on some claims, but not others, 

Hensley provides a two-step analysis for determining the reasonableness of a fee award: (1) “we ask, ‘did the plaintiff prevail on claims that were unrelated to the claims on which [her] 

succeeded?’”; and (2) “we ask whether ‘the plaintiff 

achieve[d] a level of success that makes the hours reasonably 

expended a satisfactory basis for making a fee award?’” Ibrahim v. U.S. Dep’t of Homeland Sec., 912 F.3d 1147, 1172 (7th Cir. 

2019) (quoting Hensley, 461 U.S. at 434) (alteration in original). 

The Park District’s challenge focuses only on the first of the 

two steps. 
No. 20-3492 9

A district court should not award attorneys’ fees for work 

on an unsuccessful claim “that is distinct in all respects from 

[the plaintiff’s] successful claim.” Hensley, 461 U.S. at 440. But 

if the “lawsuit consists of related claims, a plaintiff who has 

won substantial relief should not have his attorney’s fee reduced simply because the district court did not adopt each 

contention raised.” Id. We have explained that unrelated 

claims are those that “are entirely distinct and separate from 

the prevailing claims.” Ibrahim, 912 F.3d at 1174 (quotation 

omitted). Related claims, in contrast, “involve a common core 

of facts or are based on related legal theories;” there is no requirement that “both facts and law” be in common. Id. (quotation omitted). Stated differently, the relatedness analysis centers on “whether the unsuccessful and successful claims arose 

out of the same course of conduct. If they didn’t, they are unrelated under Hensley.” Id. (quotation omitted). 

We are not convinced by the Park District’s arguments 

that the district court misapplied Hensley’s relatedness standard. As a preliminary matter, the court found that SimmonsGill voluntarily eliminated time entries that concerned “only

[] claims on which [Vega] did not prevail.” It then considered 

whether her unsuccessful claims “had a common core of facts 

or a factual nexus with the claim on which she prevailed,” and 

agreed that it did. That conclusion was reasonable. The court 

explained that Vega’s “unsuccessful claims and her successful 

[Title VII] national-origin discrimination claim were all 

bound up together in the same essential course of events consisting of the investigation of [Vega’s] timesheets and her ultimate termination[,]” that “all of the relevant events occurred 

in a very short period of time[,]” and that “evidence on the 

unsuccessful claims may have provided context for the jury 

regarding [Vega’s] entire experience as one of the [Park 
10 No. 20-3492 

District’s] employees.” And at oral argument Vega maintained that she presented the same evidence for both her Title 

VII and her § 1983 claims at trial. When presented an opportunity to contradict that representation, the Park District demurred. 

To be sure, we have recognized that some cases might present retaliation and discrimination claims that are “so discrete 

that a plaintiff who succeeds on only one claim would merit 

only a drastically reduced fee award.” Merriweather v. Family 

Dollar Stores of Indiana, Inc., 103 F.3d 576, 584 (7th Cir. 1996). 

But, as discussed, the district court reasonably concluded that 

Vega’s claims were not so discrete. So “we defer, as we must, 

to the judgment of the trier of fact.” Id. 

We also reject the Park District’s overly simple argument 

concerning Vega’s unsuccessful cross-appeal of her § 1983 retaliation claim. In essence, the Park District suggests that because the district court held that Vega’s § 1983 cross-appeal 

was unrelated to Vega’s successful claim, it follows that 

Vega’s § 1983 claim, in general, was unrelated to her successful claim. But here, too, the district court’s approach was reasonable. As a preliminary matter, Vega represented at oral argument that she voluntarily eliminated entries from her fee 

petition concerning her cross-appeal. And in the November 

16 order, the district court agreed with the Park District that 

20 hours of work on the cross-appeal it identified in Vega’s 

supplemental fee petition should not be considered. But the 

district court rejected the Park District’s argument that other 

time entries were attributable to her cross-appeal, reasoning 

that the Park District failed to identify the entries to which it 

objected. That approach was reasonable. Wachovia Secs., LLC, 

674 F.3d at 759. Moreover, the district court reasonably 
No. 20-3492 11

concluded that Simmons-Gill’s work on the § 1983 cross-appeal—that Vega lost—did not contribute to Vega’s overall 

success; in contrast, gathering and presenting evidence for 

Vega’s § 1983 claim at trial directly contributed to it. 

3 

The Park District then asserts that the district court unreasonably awarded attorneys’ fees for excessive billable hours. 

The Court in Hensley held that parties submitting fee requests 

“should make a good faith effort to exclude ... hours that are 

excessive, redundant, or otherwise unnecessary just as a lawyer in private practice ethically is obligated to exclude such 

hours from his fee submission.” 461 U.S. at 434. This principle 

follows from counsel’s obligation to exercise “billing judgment,” which in part requires that “[h]ours that are not 

properly billed to one’s client also are not properly billed to 

one’s adversary pursuant to statutory authority.” Id. (quotation omitted). Accordingly, counsel must “winnow[] the 

hours actually expended to the hours reasonably expended.” 

Spegon, 175 F.3d at 552. The district court, in turn, must exclude “hours that were not reasonably expended.” Hensley, 

461 U.S. at 434 (quotation omitted). 

That said, the “essential goal in shifting fees ... is to do 

rough justice, not achieve auditing perfection.” Fox, 563 U.S. 

at 838. To that end, the Court has noted that district courts 

may consider “their overall sense of the suit” and “may use 

estimates in calculating and allocating an attorney’s time.” Id.

And, along the same lines, we do not require a district court 

to “undertake a line-by-line inquiry” of a voluminous fee petition and have “endorse[d] the [district] court’s lump-sum 

approach as a practical means of trimming fat from a fee 
12 No. 20-3492 

application.” Nichols, 4 F.4th at 444 (quoting Tomazzoli v. 

Sheedy, 804 F.2d 93, 98 (7th Cir. 1984) (alteration omitted)). 

The district court reasonably accounted for what it 

deemed excessive billing requests in both the July 20 and November 16 orders. In its July 20 order, the district court analyzed Simmons-Gill’s fee petition line by line and excluded 

plainly deficient entries after Simmons-Gill had already voluntarily eliminated certain entries. It then reduced the total 

amount of fees Simmons-Gill sought by 5%. The court reasoned that for the most part the billing entries would be acceptable to paying clients; that the Park District’s tactics accounted in part for the higher billable hours Simmons-Gill 

recorded; and that Simmons-Gill billed many of those hours 

at the lower billing rates of associates or paralegals. In the November 16 order, the district court noted that Vega submitted 

affidavits from employment law practitioners supporting the 

reasonableness of Simmons-Gill’s billable hours. It went on to 

note the multitude of issues and high stakes in the litigation 

and that Vega’s level of success at trial warranted “a substantial level of effort to protect the verdict.” And it found the Park 

District offered no basis for its argument otherwise “apart 

from its own ipse dixit.” See Wachovia Secs., LLC, 674 F.3d at 

759. 

In resisting the district court’s analysis, the Park District 

argues that the district court arbitrarily eliminated certain redacted entries while leaving others. We disagree. As a preliminary matter, the district court did not turn a blind eye to the 

redacted entries; rather, it first eliminated entries that it found 

to be plainly deficient and then reduced the total fee request 

by 5%, explaining the reasons for the reduction. That analysis, 

as we discussed, was reasonable. So even if certain entries 
No. 20-3492 13

were as deficient as those the district court specifically excluded, the district court accounted for that deficiency in a 

way we have recognized is reasonable. Given the highly deferential standard of review, the district court’s analyses in its 

July 16 and November 20 orders were reasonable. 

4 

The Park District also takes issue with the district court’s 

decision to use Simmons-Gill’s current, rather than historical, 

billing rates. “A reasonable hourly rate is based on the local 

market rate for the attorney’s services.” Montanez v. Simon, 

755 F.3d 547, 553 (7th Cir. 2014). The “best evidence” of that 

rate “is the amount the attorney ... bills for similar work.” Id.

The district court may also “rely on evidence of rates charged 

by similarly experienced attorneys in the community and evidence of rates set for the attorney in similar cases.” Id. Vega 

has the burden of proving the market rate; “however, once the 

attorney provides evidence of the market rate, the burden 

shifts to the opposing party to show why a lower rate should 

be awarded.” Stark v. PPM Am. Inc., 354 F.3d 666, 675 (7th Cir. 

2004). The district court’s “hourly rate determinations” are 

“afforded great deference so long as” the evidence the district 

court relies upon is “sufficiently recent to be probative of 

counsel’s” market rates. Spegon, 175 F.3d at 557. We have affirmed district courts’ use of counsel’s historical market rates, 

see Smith v. Village of Maywood, 17 F.3d 219, 221 (7th Cir. 1994), 

and current market rates in multi-year litigation. See Lightfoot 

v. Walker, 826 F.2d 516, 523 (7th Cir. 1987). As for the latter, a 

current market rate calculation “compensate[s] for the delay 

in payment” and “simplif[ies]” the district court’s calculation. 

Id.
14 No. 20-3492 

Although we are skeptical of using current billing rates in 

litigation that lasts as long as this case did, we cannot say that 

the district court’s decision to use Simmons-Gill’s current billing rates under the circumstances was unreasonable given the 

degree of deference we afford district courts. It was certainly 

reasonable for the district court to rely upon Vega’s submissions—declarations from employment attorneys, an unexecuted hourly fee agreement, and Simmons-Gill’s agreements 

to serve as an expert witness—to determine Simmons-Gill’s 

current billing rates. See Spegon, 175 F.3d at 557. We also agree 

with the district court that using counsel’s current billing rates 

has the virtue of simplicity and that it is appropriate for courts 

to account for a delay in payment. But, as we cautioned in 

Lightfoot, district courts should avoid awarding current billing 

rates when it results in a “windfall[,]” particularly in yearslong litigation. 826 F.2d at 523. This litigation was exceptionally long, even for multi-year Title VII litigation. And applying the current billing rates without adjustment gives us 

pause—the applied rate is over 40% higher than SimmonsGill’s billing rate when the litigation commenced. The district 

court could have gone about this another way by using the 

historical billing rates at the time the work was performed 

plus compensating for the delay in payment, and could have 

provided a more robust explanation for its decision to apply 

current rates when the billings stretched over so many years. 

But, in the end, we are not convinced that the district court’s 

approach under the circumstances in this case—using current 

billing rates as a means to compensate for the delay in 
No. 20-3492 15

payment—was unreasonable under our highly deferential 

abuse of discretion standard.3 

* * * 

We end our analysis of the district court’s attorneys’ fees 

award where we started, with the standard of review in fee 

litigation appeals. The attorneys’ fees in this case strike us as 

rather high for the type of litigation and monetary and equitable relief that Vega achieved. But our review is highly deferential, and the district court’s analysis and reasoning 

demonstrate an appropriate exercise of its discretion. 

B 

The Park District finally takes issue with the district 

court’s calculation of the tax-component award. We review a 

district court’s grant of a tax-component award for abuse of 

discretion. Vega, 954 F.3d at 1009–10. 

The district court used the same three-step formula that 

the district court in Washington used to calculate the award: 

(1) subtract[] the plaintiff’s actual tax burden 

during the back-pay period from the tax burden 

she would have born during the same period 

had she remained employed by the defendant, 

(2) subtract[] the plaintiff’s expected tax burden 

in the year of the decision, absent any lump-sum 

back-pay award, from that portion of her expected tax burden attributable to the back-pay 

award in the event that a lump-sum payment 

3 We note that the district court may have reduced the lodestar (that is, 

reasonable fees multiplied by reasonable hours) by 5% across the board 

to, at least in part, reduce Simmons-Gill’s billing rate, but it did not say so. 
16 No. 20-3492 

was made in the same year, and (3) subtract[] 

the result of (1) from the result of (2). 

See Washington, 2016 WL 5233563, at *4. Following these steps 

in detail, the district court arrived at a $49,224.30 tax-component award. 

The Park District does not object to the Washington framework.4 Rather, it maintains that the district court abused its 

discretion for two reasons: (1) portions of Vega’s tax returns 

from 2013 to 2017 were redacted—Vega’s adjusted gross income, deductions, and taxable income—which made it impossible for the district court to accurately calculate Vega’s 

hypothetical tax liability had she remained employed with 

the Park District for those years; and (2) the district court 

erred when it included the $300,000 compensatory damages 

award to calculate Vega’s effective tax rate. 

Both arguments fall flat. As for the first, Vega presented 

evidence of her actual tax burden ($0) for each year from 2013 

to 2017 and testified to what she would have owed in taxes if 

employed by the Park District during that period. That testimony was based on Vega’s actual tax burden while employed 

with the Park District from 2010 to 2012. So the district court 

reasonably credited this evidence. Indeed, the Park District 

presented nothing to contradict it, even though the Park District—as her former employer—could have deduced a hypothetical tax liability based on what it would have paid Vega. 

Because the district court had ample, uncontradicted evidence to employ the Washington methodology, it did not 

abuse its discretion when doing so. Moreover, the Park 

4 We do not go so far as to hold that Washington provides the exclusive 

formula for calculating a tax-component award. 
No. 20-3492 17

District does not identify, and our research does not reveal, a 

case requiring certain information (here, unredacted tax returns) to calculate hypothetical tax liability. We do not impose 

such a requirement now. 

The Park District’s second argument asks us to hold, as a 

matter of law, that including compensatory damages to calculate Vega’s effective tax rate was error, but we see no reason 

to impose that requirement either. No other circuit has placed 

such a limit on the district court’s wide discretion to make a 

plaintiff whole through a tax-component award. Rightly so. 

Title VII affords wide latitude to fashion an award that fits the 

“circumstances peculiar to the case”—in other words, the 

plaintiff’s circumstances. E.E.O.C. v. N. Star. Hosp., 777 F.3d 

898, 904 (7th Cir. 2015) (quotation omitted); see also 42 U.S.C. 

§ 2000e–5(g)(1) (stating a court may award, among other 

things, “any other equitable relief as the court deems appropriate”). And while some district courts have considered compensatory damages when calculating a plaintiff’s hypothetical tax liability in exercising their discretion, others have not. 

In sum, the Park District does not articulate any sufficient basis—statutory or otherwise—upon which to limit a district 

court’s wide discretion in computing tax-component awards. 

AFFIRMED