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Law School Case Brief

Shadis v. Beal - 685 F.2d 824 (3d Cir. 1982)


Public policy against the enforcement of promises or other terms may be derived by the court from legislation relevant to such a policy, or the need to protect some aspect of the public welfare.


Appellee benefit recipients filed a lawsuit alleging that appellants, state officials and agencies, violated their civil rights by depriving them of medical benefits. Appellees were represented by Community Legal Services (CLS), a non-profit legal services corporation. The district court awarded attorneys’ fees to CLS and the appellants challenged the judgment, holding that contractual provisions between CLS and the state were void because they conflicted with the public policy underlying the Fees Awards Act.


Is the no fees restraint of the contract between the state and the appellees’ legal representative valid and enforceable?




The Court affirmed the ruling of the trial court, holding that the no fees restraints of the contracts were unenforceable. The court found that the provisions counteracted the federal public policy underlying the act because legal service programs for the poor would have had less incentive and ability to bring civil rights suits against the state. Moreover, the factors in favor of enforcement were outweighed by the public policies weighing against enforcement.

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