Laquarius Gray, a nine-year-old student, sued Deputy Antonio Bostic after he handcuffed her for less than a minute during a school incident. Earlier appeals established a Fourth Amendment violation, and a jury ultimately awarded Gray one dollar in nominal damages. The appeal here concerns the district court’s later award of more than $39,900 in attorney’s fees and expenses under 42 U.S.C. § 1988. The Eleventh Circuit held that Gray’s victory was de minimis under the three-factor framework from Farrar v. Hobby. She obtained no compensatory or punitive damages, no injunction, and no showing that the litigation changed law or established a broader public purpose. The court also held that the district court applied an improper standard by treating attorney’s fees themselves as the deterrent and by using fees to enhance the significance of the jury’s nominal-damages verdict. The court reversed the fee award and remanded for entry of judgment for Bostic on the fee claim. Judge Wilson dissented, reasoning that the litigation vindicated an important constitutional right and that the district court had not abused its discretion.