Watson

We hold today that a plaintiff who succeeds in obtaining a preliminary injunction can be deemed a “prevailing party” for purposes of 42 U.S.C. § 1988 , even though he did not recover other relief sought in the lawsuit. We also hold that a district court does not abuse its discretion when it declines to assess against a defendant attorney’s fees incurred by a plaintiff in opposing a motion to intervene brought by strangers to the lawsuit.

I. Facts

Tracy Watson, a former Riverside County deputy sheriff, participated in a highly publicized vehicle chase that culminated in the arrest of certain individuals. Watson wielded his police baton during the arrest and was suspected of using excessive force. Upon returning to the sheriffs station, he *1094 was ordered to prepare a report of the incident. Watson alleged that he was denied the opportunity to consult with a lawyer prior to writing his report. Upon completion of his report, Watson was placed on administrative leave and eventually terminated.

Watson brought an action in the U.S. District Court alleging that the county and various individual deputies violated his Fourth, Fifth and Fourteenth Amendment rights by detaining…