Texas State Teachers Ass'n v. Garland Independent School District

Summary

The Supreme Court held that a civil-rights plaintiff qualifies as a prevailing party under 42 U.S.C. § 1988 when it succeeds on any significant issue and obtains some of the benefit sought, materially altering the legal relationship between the parties. The Court rejected the Fifth Circuit’s “central issue” and “primary relief sought” tests, explaining that the degree of overall success affects the reasonableness of the fee award rather than eligibility for fees. The judgment was reversed and remanded for determination of a reasonable attorney’s fee.

Holdings

1. A civil-rights plaintiff is a prevailing party if the plaintiff succeeds on any significant issue in the litigation and obtains some of the benefit sought, producing a material alteration of the legal relationship between the parties. The plaintiff need not prevail on the litigation's central issue or obtain the primary relief sought.
2. Petitioners were prevailing parties under § 1988 because their judgment vindicating teachers' First Amendment rights materially altered the school district's policy and provided some of the relief sought.

Questions Presented

1. What standard determines whether a civil-rights plaintiff is a prevailing party eligible for attorney's fees under 42 U.S.C. § 1988?
2. Whether petitioners were prevailing parties despite losing on some claims and obtaining only partial relief.

Disposition

reversed_and_remanded