Catharina Laan v. Debbe Lancaster, in her individual and official capacity as Yukon Flats School District Superintendent, et al.; Michelle McGovern v. Debbe Lancaster, in her individual and official capacity as Yukon Flats School District Superintendent, et al.

Summary

The United States District Court for the District of Alaska denied defendants’ motions for attorney fees under 42 U.S.C. § 1988 against Catharina Laan and Michelle McGovern. Although summary judgment had been entered for defendants in the consolidated cases involving plaintiffs’ termination for refusing vaccination, the court found that their civil rights claims were not frivolous, unreasonable, or groundless, while directing that defendants receive taxable costs.

Holdings

1. Prevailing defendants may recover attorney fees in a § 1983 action only when the plaintiff's civil-rights claim was frivolous, unreasonable, or groundless, or when the plaintiff continued litigating after the claim clearly became so. Because Plaintiffs' claims were not frivolous, unreasonable, or groundless, Defendants were not entitled to attorney fees.
2. Defendants were entitled to costs identified in their bills of costs because Plaintiffs did not overcome the presumption that costs should be taxed in favor of the prevailing party.

Questions Presented

1. Whether prevailing defendants were entitled to attorney fees under 42 U.S.C. § 1988 after obtaining summary judgment on the plaintiffs' § 1983 claims.
2. Whether Defendants were entitled to costs as prevailing parties when Plaintiffs did not overcome the presumption favoring taxation of costs.

Disposition

other