Christiansburg Garment Co. v. Equal Employment Opportunity Commission

Background

A private clothing company and the federal equal-employment agency (the Commission) disputed whether the agency could sue on an old discrimination charge after 1972 amendments. The agency sued under the new law, the company won summary judgment because the earlier charge was not “pending,” and the company then asked the courts to make the agency pay the company’s attorney’s fees. Lower courts denied fees, finding the agency’s suit was not unreasonable, and the case reached the Court to decide when a winning defendant can recover fees.

Reasoning

The key question was when a defendant who wins a discrimination suit may obtain the other side’s lawyer fees. The Court explained that while prevailing plaintiffs ordinarily get fees to encourage enforcement, prevailing defendants should recover fees only in different, narrower circumstances. The Justices rejected two extremes — treating defendants exactly like successful plaintiffs or allowing fees only when the plaintiff acted in bad faith. The Court adopted a middle standard: a court may award fees to a winning defendant if the plaintiff’s claim was frivolous, unreasonable, or without foundation. The Court warned judges not to punish plaintiffs simply because they later lose and upheld the lower court’s decision here because the agency raised an issue of first impression and its position was not frivolous.

Real world impact

The ruling gives trial judges clear guidance: defendants can get fees but only for groundless claims, protecting defendants from abusive suits while not deterring honest but uncertain discrimination claims. It also notes fee awards against the agency come from its enforcement budget, so such awards affect public enforcement resources.