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The Civil Rights Attorney's Fees Awards Act of 1976 provides that 'the court, in its discretion, may allow the prevailing party . . . a reasonable attorney's fee' in enumerated civil rights actions. 90 Stat. 2641, 42 U.S.C. § 1988. In Maher v. Gagne, 448 U. S. 122 (1980), the court held that fees may be assessed against state officials after a case has been settled by the entry of a consent decree. 

It is well established that a defendant may settle, for a single lump sum, all outstanding claims in a fee-shifting case, including claims for attorney fees. Evans v. Jeff D., 475 U.S. 717, 731-32, 106 S. Ct. 1531, 89 L. Ed. 2d 747 (1986) (Congress intended fee awards to be part of civil rights plaintiff's 'arsenal of remedies,' and settlement including waiver of award is consistent with this goal). 

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