Newman v. Piggie Park Enterprises, Inc.

Background

A group of people sued several South Carolina restaurant owners after proving that the owners refused service to Black customers at five drive-in restaurants and a sandwich shop. The trial court found discrimination at all six locations but declined to limit the restaurants’ operations under the Civil Rights Act for the drive-ins, so it enjoined only the sandwich shop. A federal appeals court reversed that part of the ruling and raised the question of when a winning plaintiff should receive payment for lawyers under the Act.

Reasoning

The Court addressed whether a plaintiff who wins an injunction under Title II should get reasonable attorney’s fees only when the defendant acted in bad faith, or more broadly. The Court explained that Title II relies heavily on private lawsuits to enforce the law and that a successful plaintiff acts as a “private attorney general” vindicating an important public policy. To make sure people can bring these suits, the Court held that a prevailing plaintiff should ordinarily recover attorney’s fees unless special circumstances make a fee award unjust. The Court found no such circumstances here and rejected the stricter bad-faith-only rule.

Real world impact

The decision means courts should usually award reasonable lawyers’ fees to people who win injunctions stopping racial discrimination in public places, which reduces the financial barrier to suing. The case was sent back so the trial court can include a fee award; the opinion notes that the defendants had offered frivolous defenses, so fees are appropriate in this instance. This rule is meant to encourage private enforcement of civil-rights laws nationwide.