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27 Ohio 75 Notre Dame alleged apply Athletic attorney's fees automatic stay Brentwood Academy catalyst rule catalyst theory Circuit Civil Rights claim clearly established conduct violated Congress consent decree consent judgment correct the violation Court held Court of Appeals decision defendant defendant's discrimination dissent District Court due process Eighth Amendment Eleventh Amendment employer end of Note enforcement entitled to qualified excessive force federal courts Federal right fee-shifting Fourteenth Amendment Fourth Amendment Gates Gender Gonzaga University handcuffed Hayburn's hitching post implied right inmates judgment judicial Justice lawsuit legislative ment Municipal Liability necessary to correct Ohio N.U.L. Rev petitioner plaintiff PLRA police prevailing party prison guards private right prohibits prospective relief provides qualified immunity regulation remedy Rendell-Baker respondents restraining bar right of action S.Ct Section Seminole Tribe Sexual Harassment Sexual Harassment Law Sovereign Immunity statute statutory suit supra Supreme Court terminate tion Title IX Title VII violated the Eighth