CRST Van Expedited, Inc. v. Equal Emp't Opportunity Comm'n
The Supreme Court ruled that a company sued for workplace discrimination can be a "prevailing party" eligible for attorney's fees even when the lawsuit was dismissed on procedural grounds rather than decided on the substance of the claims.
The decision overturns an appeals-court rule that had required a merits ruling before a defendant could recover fees, making it easier for companies to recoup litigation costs when the EEOC or private plaintiffs bring cases that are later dismissed on technical grounds.
“The defendant has, however, fulfilled its primary objective whenever the plaintiff's challenge is rebuffed, irrespective of the precise reason for the court's decision.”
The Court's core reasoning for why a defendant can prevail without a ruling on the merits.
How it got here: Federal district courts repeatedly dismissed the EEOC's claims and awarded CRST fees; the Eighth Circuit twice reversed, ultimately requiring a merits ruling before fees could be awarded.
The Case in Depth
What happened
A truck driver named Monika Starke accused two male trainers at CRST, a trucking company, of sexually harassing her during a required training trip. The EEOC investigated, found reasonable cause, and eventually sued CRST on behalf of Starke and over 250 other women. Courts dismissed nearly all these claims, many because the EEOC had not properly investigated or tried to resolve them before suing, and CRST sought over $4 million in attorney's fees as the winning party.
The question before the Court
Can a company that gets sued for job discrimination and wins count as a "prevailing party" entitled to attorney's fees, even if the case was thrown out for reasons that never touched the merits?
The Court's answer
Yes — the Court ruled that a company does not need a ruling on the actual substance of a discrimination claim to count as the "prevailing party" entitled to attorney's fees. A defendant's real goal in litigation is simply to stop the plaintiff from getting what it wants, and that goal is met whenever a claim is rejected, whatever the legal reason.
The Court reasoned that Congress's fee-shifting law was meant to protect defendants from frivolous, unreasonable, or groundless lawsuits, and that purpose does not depend on whether the case was thrown out for a procedural reason (like a missed deadline) or a merits reason. The Court did not decide two related questions the EEOC raised late in the case — whether a defendant must win a "preclusive" judgment to prevail, and whether the EEOC's own conduct here was unreasonable — leaving those for the lower courts.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Employers facing discrimination lawsuits — especially large EEOC actions covering many workers — can now seek attorney's fees even when a case is dismissed for procedural reasons like a missed filing deadline or a failure to properly investigate before suing. This gives companies a stronger financial deterrent against weak or sprawling claims, while plaintiffs' advocates worry it could discourage aggressive civil-rights enforcement.
What changes now
The case goes back to the Eighth Circuit to apply the correct legal standard: it must now decide whether CRST actually prevailed on each of the claims dismissed on procedural grounds and, separately, address the EEOC's arguments — raised late in the litigation — about whether a defendant must obtain a 'preclusive' judgment to prevail and whether the EEOC's presuit conduct was unreasonable. These unresolved issues could still affect the final size of any fee award.
What this does not decide
The Court did not decide whether a defendant must obtain a legally 'preclusive' judgment to be a prevailing party, nor whether the EEOC's failure to investigate and conciliate the 67 claims was actually unreasonable enough to justify fees. Both issues were left for the Eighth Circuit to resolve on remand.
Concurrences and dissents
Concurrence — Justice Thomas
Justice Thomas joined the Court's opinion in full but wrote separately to reiterate his long-held view that the Court's 1978 Christiansburg decision — which makes it harder for prevailing defendants than prevailing plaintiffs to recover fees — wrongly departed from the statute's actual text. He said he continues to view Christiansburg as a 'dubious precedent' he will not extend further.
How the Court got there
The legal reasoning, step by step
- The Court identified the touchstone test for who counts as a 'prevailing party' in fee-shifting cases: whether there has been a material alteration in the legal relationship between the parties, backed by a court's official action (sometimes called 'judicial imprimatur').
- Applying that touchstone, the Court reasoned that while a plaintiff wins by getting a court to change the legal relationship in its favor, a defendant wins simply by preventing that change — regardless of why the court ruled against the plaintiff.
- The Court found no sign that Congress meant to limit defendants' fee eligibility to cases decided on the merits; the fee-shifting statute's purpose, deterring frivolous or groundless lawsuits, applies just as much to cases dismissed on procedural grounds.
- The Court supported this reading by pointing out that its own precedent, Christiansburg Garment Co. v. EEOC, had allowed a defendant to recover fees in a case dismissed for a non-merits, timing-related reason, without treating that as disqualifying.
- The Court noted that several federal appeals courts had already awarded defendants' fees in cases dismissed on non-merits grounds like sovereign immunity or mootness, reinforcing that a merits ruling was never required.
- Because Congress's intent and consistent lower-court practice both pointed away from a merits-only rule, the Court concluded that the Eighth Circuit's requirement of a 'ruling on the merits' was legally incorrect.
Doctrinal impact
Cases affected by this decision
Reaffirms Christiansburg Garment Co. v. EEOC (434 U.S. 412)
The Court relied on Christiansburg's fee-shifting standard as still controlling, rejecting a stricter merits-only rule.