Raza Siddiqui v. National Association of Broadcast Employees & Technicians - Communications Workers…

In the
United States Court of Appeals
For the Seventh Circuit
____________________
No. 24-2315
R AZA S IDDIQUI , et al.,
Plaintiffs-Appellants,
v.
NATIONAL A SSOCIATION OF BROADCAST EMPLOYEES &
TECHNICIANS – C OMMUNICATIONS WORKERS OF A MERICA, et al.,
Defendants-Appellees.
____________________
Appeal from the United States District Court for the
Northern District of Illinois, Eastern Division.
No. 1:22−cv−05732 — Manish S. Shah, Judge.
____________________
A RGUED J ANUARY 28, 2025 — DECIDED M ARCH 24, 2025
____________________
Before HAMILTON , K IRSCH , and M ALDONADO, Circuit
Judges.
K IRSCH , Circuit Judge. Members of a local union sued their
national parent organization for imposing an illegal trustee-
ship. The parties eventually resolved the case by entering into
a consent judgment, leaving only one decision for the district
court: whether to award attorneys’ fees to the local union
members. The district court declined to do so. Because it did

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2 No. 24-2315
not abuse its substantial discretion to make that decision, we
affirm.
I
This case involves a dispute between a national labor un-
ion and members of one of its local unions. Defendants are the
National Association of Broadcast Employees and Techni-
cians, the Broadcasting and Cable Television Workers Sector
of the Communications Workers of America (NABET-CWA),
and three union executives. Plaintiffs are members of
NABET-CWA Local 41 (Local 41), including plaintiff Raza
Siddiqui. We refer to defendants collectively as the national
union and plaintiffs collectively as Siddiqui.
The dispute giving rise to this appeal began when the na-
tional union placed Local 41 under a temporary trusteeship in
the wake of a Local 41 officer election. Siddiqui sued the na-
tional union under § 304(a) of the Labor-Management Report-
ing and Disclosure Act (LMRDA), 29 U.S.C. § 464(a), for im-
posing the trusteeship illegally. The district court agreed with
Siddiqui that the national union had imposed the trusteeship
in bad faith and granted Siddiqui a temporary restraining or-
der, which it later converted into a preliminary injunction. Af-
ter settlement negotiations and some motion practice, the dis-
trict court entered a consent judgment at the parties’ request.
This consent judgment converted the preliminary injunction
into a permanent injunction that dissolved the trusteeship
and required the national union to pay Local 41 about $26,000
in trusteeship costs. The consent judgment resolved all issues
in the case but one: whether Siddiqui was entitled to recover
attorneys’ fees from the national union (and, if so, how much).
The parties briefed the issue, and, in the end, the district court

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No. 24-2315 3
denied Siddiqui’s request for attorneys’ fees in an oral ruling
from the bench.
In its oral ruling, the district court noted its broad discre-
tion to decide whether to award fees and recognized the pre-
sumption in American law against doing so, known as the
American Rule. See Hall v. Cole, 412 U.S. 1, 4–5 (1973); Alyeska
Pipeline Serv. Co. v. Wilderness Soc’y, 421 U.S. 240, 245 (1975).
Although it found two exceptions to the American Rule could
apply, it determined neither justified fee shifting.
First, the district court discussed the bad faith exception.
Under this exception, if the losing party acted “vexatiously,
wantonly, or for oppressive reasons”—in other words, in bad
faith—a district court may award attorneys’ fees as a compen-
satory measure. Hall, 412 U.S. at 5 (quotation omitted); Good-
year Tire & Rubber Co. v. Haeger, 581 U.S. 101, 107–08 (2017).
The district court decided that the national union imposed the
trusteeship in bad faith but that both sides litigated the ensu-
ing dispute in good faith. So, it concluded the degree of bad
faith did not justify fee shifting.
Second, the district court considered whether Siddiqui
had generated common benefits. The common benefit excep-
tion “involves cases in which the plaintiff’s successful litiga-
tion confers a substantial benefit on the members of an ascer-
tainable class, and … an award … operate[s] to spread the
costs proportionately among them.” Hall, 412 U.S. at 5 (quo-
tation omitted). Before analyzing the applicability of this ex-
ception, the district court briefly pondered its continuing vi-
tality. It said, “I’m not so sure that the contemporary concep-
tion of federal judicial power includes this common benefit
principle in the absence of any congressional action.” And it
wondered whether today’s Supreme Court “might even

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4 No. 24-2315
conclude that Hall was wrongly decided.” Continuing, “I
have no opinion on that,” the district court then assessed the
exception anyway. It found Siddiqui conferred common ben-
efits on Local 41 and the national union, but it ultimately con-
cluded neither benefit was so great that it merited an award
of attorneys’ fees.
Siddiqui now appeals, arguing the district court commit-
ted reversible error by declining to grant him fees given its
bad faith and common benefit findings. He argues the district
court’s observations on the common benefit exception are fur-
ther evidence of faulty reasoning that justify reversal.
II
We review a district court’s decision whether to award at-
torneys’ fees for abuse of discretion. Chambers v. NASCO, Inc.,
501 U.S. 32, 55 (1991). A district court abuses its discretion “if
it reaches an erroneous conclusion of law … or reaches a con-
clusion that no evidence in the record supports as rational.”
In re Stericycle Sec. Litig., 35 F.4th 555, 559 (7th Cir. 2022) (quo-
tation omitted). As long as the district court provides some
explanation for its decision, we will not overturn that decision
unless no reasonable person would agree with it. REXA, Inc.
v. Chester, 42 F.4th 652, 671, 673–74 (7th Cir. 2022).
Siddiqui argues that our standard of review should in-
stead be de novo, but he is incorrect. He bifurcates the district
court’s fee decision, arguing that we review de novo the initial
evaluation of a plaintiff’s entitlement to fees and conceding
only that we review for abuse of discretion any resultant
choice about the amount of fees to award. It is true that any
legal analysis related to fee determinations receives de novo
review. Stericycle, 35 F.4th at 559. But this appeal does not

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No. 24-2315 5
present a question of legal analysis. Siddiqui does not chal-
lenge the legal framework the district court set out for its fees
determination, only the decision the court made after
properly applying that framework. Contrary to Siddiqui’s ar-
gument, we review the threshold decision whether plaintiffs
are entitled to fees for abuse of discretion. Aaron v. Mahl, 550
F.3d 659, 667 (7th Cir. 2008). In short, the district court’s dis-
cretion to award attorneys’ fees encompasses both when to
award fees and in what amount.
We have said time and again that our review of a district
court’s discretion on this matter is “highly deferential.” E.g.,
Paz v. Portfolio Recovery Assocs., LLC, 924 F.3d 949, 954 (7th Cir.
2019) (quotation omitted); Est. of Borst v. O'Brien, 979 F.2d 511,
514 (7th Cir. 1992) (“We can think of few matters more waste-
ful of judicial resources than ancillary litigation over an attor-
neys’ fee award.”). Such decisions receive “significan[t] def-
erence” and “wide latitude.” Pickett v. Sheridan Health Care
Ctr., 664 F.3d 632, 639 (7th Cir. 2011) (quotation omitted). “If
ever there was a case for reviewing the determinations of a
trial court under a highly deferential version of the ‘abuse of
discretion’ standard,” it is in the case of attorneys’ fees. Ustrak
v. Fairman, 851 F.2d 983, 987 (7th Cir. 1988). Our review is so
deferential because “(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 mi-
nutia; and (3) the desirability of avoiding a second major liti-
gation strictly over attorneys’ fees is high.” Vega v. Chi. Park
Dist., 12 F.4th 696, 702 (7th Cir. 2021) (alteration in original)
(quotation omitted).

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6 No. 24-2315
Although district courts’ equitable discretion regarding
attorneys’ fees is well established, the American Rule pre-
sumes against fee shifting. Hall, 412 U.S. at 4–5. “In the United
States, the prevailing litigant is ordinarily not entitled to col-
lect a reasonable attorneys’ fee from the loser.” Alyeska Pipe-
line, 421 U.S. at 247. Further, the bad faith and common benefit
exceptions to the American Rule are permissive, not manda-
tory. That is because the power to award attorneys’ fees is it-
self a discretionary, inherent, equitable power—a point Sid-
diqui admitted before the district court. Hall, 412 U.S. at 4–5.
Courts should preserve these exceptions “for situations in
which overriding considerations indicate the need” to award
attorneys’ fees. Mills v. Elec. Auto-Lite Co., 396 U.S. 375, 391–
92 (1970).
The district court dutifully set out and applied the Ameri-
can Rule and two of its exceptions. It did not need to conduct
any further legal analysis. It did not abuse its discretion when
it then declined to exercise its equitable discretion to award
attorneys’ fees.
The district court appropriately assessed the bad faith ex-
ception and reasonably concluded that the national union’s
bad faith imposition of the trusteeship did not create an over-
riding need to award fees. It found the parties’ subsequent
good faith litigation served as a counterbalance. And it
properly adhered to the rule that it should award attorneys’
fees only when “overriding considerations indicate the need.”
Id. It acknowledged that all bad faith trusteeships should be
deterred but concluded that such deterrence is achieved by
dissolving the trusteeship, not by awarding attorneys’ fees ab-
sent an overriding need, and thus decided not to award fees.

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No. 24-2315 7
That was a legally sound and entirely reasonable decision,
comfortably within the court’s broad discretion.
The district court likewise correctly analyzed the common
benefit exception and reached a reasonable conclusion within
its discretion. The animating principle behind this exception
is the reallocation of litigation costs so that all those who ben-
efit from the result share the expense. Alyeska Pipeline, 421 U.S.
at 245. For example, a union member who sues his union to
vindicate a free speech right to allege undemocratic actions by
union officers (a right the LMRDA assured him) has “ren-
dered a substantial service to his union as an institution and
to all of its members.” Hall, 412 U.S. at 2–3, 8. So, “reimburse-
ment of [his] attorneys’ fees out of the union treasury simply
shifts the costs of litigation to the class that … benefited from
them and that would have had to pay them had it brought the
suit.” Id. at 8–9 (quotation omitted).
Here, the district court found two common benefits. It de-
termined that Siddiqui conferred a common benefit on all un-
ion members by vindicating the principle of local governance.
But the district court didn’t think that benefit presented an
overriding need to shift fees because it was not the primary
motivator behind what the court deemed a hyperlocal, politi-
cal fight. The conflict instead centered on the mechanics of un-
ion governance, which the court considered private feuding
without general significance that did not produce the kind of
institutional success warranting fee shifting. The district court
also found Siddiqui conferred a second common benefit by
getting the national union to pay for the costs of the trustee-
ship. But it thought this benefit was modest, so it declined to
spread Siddiqui’s attorneys’ fees across the membership of ei-
ther the national union or Local 41. That is, it viewed the

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8 No. 24-2315
roughly $26,000 the national union paid Local 41 as relatively
insubstantial, so it was not concerned that failing to distribute
the fees Siddiqui spent recouping that money from the na-
tional union would unjustly enrich other union members, nor
was it worried that Siddiqui would not have sued the national
union without fee shifting. Each of these conclusions was rea-
sonable, and the district court was perfectly entitled to make
them. It did not abuse its discretion by finding common ben-
efits existed but not to a degree justifying fee shifting.
Siddiqui also asserts that the district court committed legal
error by basing its decision to deny fees on a prediction that
the current Supreme Court would overturn Hall were it pre-
sented the opportunity. The district court did no such thing.
It merely made some non-dispositive observations. It won-
dered whether the Supreme Court, writing on a blank slate
without precedent like Hall, would empower courts to award
attorneys’ fees absent statutory authorization. And it ex-
pressed doubt that the contemporary conception of federal ju-
dicial power encompasses the common benefit exception. But
the district court nonetheless applied the exception to this
case—as it must, absent contrary Supreme Court guidance—
and found it existed, just not sufficiently to warrant awarding
attorneys’ fees. Its observations were not improper and its de-
cision declining to shift fees was not an abuse of discretion.
A FFIRMED

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