In what circumstances will a plaintiff be entitled to a reduction in the amount of fees awarded to defendants in a civil rights action?

In the instant case, all of the claims arose from a "common core of facts," the search of plaintiffs' house. Further, all of the claims are "based on related legal theories," the Fourth Amendment. However, since the plaintiffs succeeded against only a few defendants, a reduction for limited success was permissible. Cabrales, 864 F.2d at 1466. ⁵ "The purpose of a fee award is to encourage litigation and voluntary compliance with civil rights laws." Woods v. Graphic Communications, 925 F.2d 1195, 1207 (9th Cir.1991) (citations omitted). In cases such as the present one, where a plaintiff brings an action against a large number of defendants, but manages to prevail only with regard to a few, perhaps an award granting 100% of the accrued

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