Lackey v. Stinnie
Headline: Court limits attorney-fee awards by ruling that temporary preliminary injunctions that become moot do not make civil-rights plaintiffs 'prevailing parties,' making fee recovery harder when only interim relief was won.
Holding: The Court held that plaintiffs who obtained only preliminary injunctive relief before their cases became moot are not "prevailing parties" under §1988(b) and thus cannot recover attorney’s fees absent enduring, judicially sanctioned relief.
- Narrower chance for civil-rights plaintiffs to recover attorney’s fees after preliminary injunctions.
- Defendants can moot cases after injunctions without triggering fee liability in many cases.
Summary
Background
A group of Virginia drivers sued the state official in charge of motor vehicle licenses after their licenses were suspended for failing to pay court fines or costs. The drivers sued under the civil-rights law (42 U.S.C. §1983) and won a preliminary injunction stopping the suspensions. Before a final judgment, the state legislature repealed the law and reinstated the licenses, and the case was dismissed as moot. The drivers then asked for attorney’s fees under §1988(b), which allows fees for a "prevailing party."
Reasoning
The Court addressed whether winning only a preliminary injunction makes someone a "prevailing party" eligible for fees under §1988(b). The majority began with the statute’s text and old dictionary meanings of "prevailing party," and relied on earlier cases that require a judicially sanctioned, enduring change in the legal relationship between the parties. The Court concluded preliminary injunctions are temporary and do not conclusively resolve the merits. It held that only enduring relief granted by a court on the merits makes a plaintiff a prevailing party and eligible for fees; outside events that moot a case do not convert a temporary order into such a judgment.
Real world impact
The ruling means some civil-rights plaintiffs who win temporary court orders but whose cases later become moot cannot recover attorney’s fees under §1988(b). The opinion notes this bright-line rule is easier for courts to apply and that Congress can change the law if it wants different results. The Court reversed the Fourth Circuit’s ruling that had allowed fees here.
Dissents or concurrances
Justice Jackson dissented, arguing many appeals courts allow fees for meaningful preliminary relief and that the majority’s rule undermines Congress’s aim to encourage civil-rights enforcement.
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