Summary
The Sixth Circuit affirmed the district court's denial of attorney's fees to Maryville Baptist Church, which had obtained a preliminary injunction against Kentucky's COVID-19 restrictions on religious gatherings before the underlying case became moot. Relying on the U.S. Supreme Court's decision in Lackey v. Stinnie, the court held that a party receiving only a preliminary injunction prior to mootness does not qualify as a prevailing party under 42 U.S.C. § 1988. Accordingly, the church was ineligible for statutory attorney's fees.
Topics
Practice areas
Questions Presented
- Whether a party that obtains only a preliminary injunction, and whose case becomes moot before final judgment, qualifies as a prevailing party for purposes of 42 U.S.C. §1988.
Holdings
- A party that receives only a preliminary injunction and whose case becomes moot does not qualify as a prevailing party under §1988 and therefore is not entitled to attorney's fees.
Key quotations
“A plaintiff “prevails,” the Court explained, “when a court conclusively resolves a claim by granting enduring judicial relief on the merits that materially alters the legal relationship between the parties.”” (at 669)
“A preliminary injunction, the Court explained, reflects only “temporary success at an intermediary stage of the suit,” not enduring relief based on a conclusive determination that the plaintiff won, and not relief that changes the relationship between the parties.” (at 667)
Factual background
Maryville Baptist Church held an Easter service in April 2020; Kentucky State Police warned attendees that the gathering violated the Governor's COVID-19 orders. The Church sued Governor Beshear under 42 U.S.C. §1983 alleging First and Fourteenth Amendment violations and obtained a preliminary injunction. The injunction became moot after the Governor lifted restrictions, and the Church later sought attorney's fees as a prevailing party.
Procedural history
The district court denied the Church's motion for attorney's fees after the Church obtained a preliminary injunction that later became moot. The Church appealed the denial.