Summary
The Supreme Court held that plaintiffs who obtain only preliminary injunctive relief before a case becomes moot do not qualify as "prevailing parties" eligible for attorney's fees under 42 U.S.C. §1988(b). The Court reasoned that preliminary injunctions are temporary and do not conclusively resolve claims on the merits or materially alter the legal relationship between the parties. This decision reverses the Fourth Circuit's en banc ruling that some preliminary injunctions could provide lasting relief qualifying plaintiffs as prevailing parties.
Topics
Practice areas
Questions Presented
- Whether a plaintiff who obtains only a preliminary injunction that becomes moot qualifies as a "prevailing party" eligible for attorney’s fees under 42 U.S.C. §1988(b).
Holdings
- Drivers who gained only preliminary injunctive relief before the action became moot do not qualify as "prevailing parties" eligible for attorney’s fees under §1988(b) because no court conclusively resolved their claims by granting enduring judicial relief that materially altered the legal relationship between the parties.
Key quotations
“A prevailing party, in other words, is "[t]he party ultimately prevailing when the matter is finally set at rest."” (at 6)
“The rule we establish today also serves the interests of judicial economy. A straightforward, bright‑line rule is easy to administer, reducing the risk of a second major litigation over attorney’s fees.” (at 10-11)
Factual background
Virginia drivers had their licenses suspended under a state statute for failure to pay court fines. They sued the Commissioner of the Virginia Department of Motor Vehicles under 42 U.S.C. §1983, claiming the statute violated due process and equal protection. The district court issued a preliminary injunction halting enforcement of the statute. Before trial, the Virginia General Assembly repealed the statute, and the parties dismissed the case as moot while seeking attorney‑fee relief.
Procedural history
Drivers whose licenses were suspended for failure to pay court fines sued the Virginia DMV commissioner under 42 U.S.C. §1983. The district court granted a preliminary injunction. The Virginia legislature repealed the statute, rendering the case moot. The district court declined attorney‑fee awards; the Fourth Circuit panel affirmed, but the Fourth Circuit en banc reversed. The Supreme Court granted certiorari to resolve whether a preliminary injunction qualifies a party as a prevailing party for fee awards under §1988(b).
Remand instructions
Remand to the district court to determine a reasonable attorney’s fee award consistent with this opinion.