In Choate v. County of Orange (2000) 86 Cal.App.4th 312, the plaintiffs prevailed in a civil rights claim for excessive force under section 1983 against several sheriff deputies. (Id. at p. 320.) The plaintiffs were awarded $5,719 in compensatory and punitive damages. (Ibid.) The trial court awarded no attorney fees to the plaintiffs. (Id. at pp. 320-321.) The appellate court affirmed the decision to deny the plaintiffs' attorney fees. (Id. at p. 318.) The appellate court found under United States Supreme Court precedent that recovering nominal damages merited no attorney fees. (Choate, supra, 86 Cal.App.4th at p. 324 quoting Farrar v. Hobby (1992) 506 U.S. 103, 115, "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.".) Considering the plaintiffs' limited success, the appellate court concluded the trial court did not abuse its discretion by awarding no attorney fees. (Choate, supra, 86 Cal.App.4th at p. 325.)