ATLANTA, GA – The Eleventh Circuit Court of Appeals has ruled that two Florida therapists who successfully challenged bans on conversion therapy in Boca Raton and Palm Beach County are entitled to a significantly higher attorney fee award than initially granted by a lower court.
The case stemmed from ordinances passed by the City of Boca Raton and Palm Beach County prohibiting therapists from engaging in “Sexual Orientation Change Efforts” (SOCE) with minors. Dr. Robert Otto and Dr. Julie Hamilton filed a lawsuit in 2018, arguing that the bans violated their First Amendment rights. They were represented by attorneys from Liberty Counsel.
After the Eleventh Circuit ruled in their favor in 2020, the plaintiffs accepted offers of judgment from the city and county. The dispute continued over the amount of attorney’s fees and costs owed. The district court originally awarded $736,887.45 in fees and expenses, but Otto and Hamilton appealed, arguing that the figure was unjustly low.
In a decision issued October 20, 2025, the Eleventh Circuit ruled that the district court erred in making a 25% across-the-board reduction in billable hours and that the correct figure should be based on a more precise evaluation of the hours worked. The appellate court recalculated the award to total $885,034.69, which includes $884,374.77 in attorney’s fees and $659.92 in costs.
The court rejected arguments that a 150% “undesirability” multiplier was warranted, as well as claims for attorney travel costs and fees incurred after the defendants’ offers of judgment. It also declined to compensate out-of-district attorneys at higher rates without a showing that local counsel was unavailable.
The case remains notable as one of the few successful challenges to municipal bans on SOCE practices, and the revised fee award reflects a reaffirmation of how prevailing parties in constitutional rights cases may be compensated under 42 U.S.C. § 1988.
