In Farrar v. Hobby, 506 U.S. 103 (1992) the United States Supreme Court held first that a party who recovers nominal damages on a 1983 claim is a prevailing party for purposes of an attorney's fees award under 1988. Then, the Court turned to the question whether attorney's fees were awardable where the plaintiffs in the case, who sought $ 17 million in compensatory damages, obtained only $ 1 in nominal damages. The jury had found that one of six defendants had deprived one of the plaintiffs of a civil right, but in an answer to a special interrogatory found that the defendant's conduct was not a proximate cause of any damages suffered by the plaintiff. Farrar, 506 U.S. at 106. In Farrar, the district court had calculated attorney's fees based upon a reasonable hourly rate multiplied by the number of hours reasonably spent on the litigation. See Farrar, 506 U.S. at 114. The Court then stated that the district court failed to engage in any measured exercise of discretion, reasoning that "'where recovery of private damages is the purpose of . . . civil rights litigation, a district court, in fixing fees, is obligated to give primary consideration to the amount of damages awarded as compared to the amount sought.'" Id. The Court in Farrar stated, "in some circumstances, even a plaintiff who formally 'prevails' under 1988 should receive no attorney's fees at all. A plaintiff who seeks compensatory damages but receives no more than nominal damages is often such a prevailing party." Id. The court said that "the awarding of nominal damages . . . highlights the plaintiff's failure to prove actual, compensable injury." Id. The Court concluded: "When a plaintiff recovers only nominal damages because of his failure to prove an essential element of his claim for monetary relief . . . the only reasonable fee is usually no fee at all." Id. The United States Supreme Court held that even though one who recovers only nominal damages under the Civil Rights Act is the "prevailing party" for attorney fees consideration, the degree of the plaintiff's overall success goes to the reasonableness of the fee award. The court upheld the reversal of a fee award of $ 280,000 in fees because, even though plaintiff "prevailed," a reasonable fee in a case involving a technical violation amounting to only nominal damages is no fee at all. The court in Johnson v. Eaton, 80 F.3d 148 (5th Cir. 1996), applied Farrar to a Federal Fair Debt Collection Protection Act case stating: "Even if Johnson's reading of the FDCPA was correct and she was entitled to receive a reasonable attorney's fee for her technical victory, Farrar makes it clear that a reasonable fee would be $ 0.00." In Farrar v. Hobby, the Supreme Court stated: "To qualify as a prevailing party, a civil rights plaintiff must obtain at least some relief on the merits of his claim. The plaintiff must obtain an enforceable judgment against the defendant from whom fees are sought, or comparable relief through a consent decree or settlement. Whatever relief the plaintiff secures must directly benefit him at the time of judgment or settlement. Otherwise the judgment or settlement cannot be said to affect the behavior of the defendant toward the plaintiff. Only under these circumstances can civil rights litigation effect the material alteration of the legal relationship of the parties and thereby transform the plaintiff into a prevailing party. In short, a plaintiff prevails when actual relief on the merits of his claim materially alters the legal relationship between the parties by modifying the defendant's behavior in a way that directly benefits the plaintiff" (id. at 111-112).