McCown

Plaintiff-Appellee Ian McCown (McCown) sued Defendants-Appellants City of Fontana, City of Fontana Police Department, Jorge Rodriguez and David Maxson (collectively, the City) alleging violations of 42 U.S.C. § 1983 , including wrongful detention, false arrest, and use of excessive force in connection with McCown’s arrest. After most of McCown’s claims were dismissed on summary judgment, the two parties settled McCown’s remaining claim for $20,000, not including attorney’s fees. The parties stipulated in the settlement agreement that McCown was the prevailing party under 42 U.S.C. § 1988 , and that the district court would determine the appropriate amount of fees and costs. The district court granted McCown attorney’s fees in the amount of $200,000, plus $15,034.10 in costs. The City appealed the award. We have jurisdiction under 28 U.S.C. § 1291 , and we reverse and remand to the district court.

FACTUAL AND PROCEDURAL BACKGROUND

On June 2, 2004, officers of the Fontana Police Department, responding to complaints of drug activity in a city park, approached a group of people that included McCown. The response team consisted of Rodriguez and Maxson as well as two other officers.…