Episode 103
Opinion Summary: Lackey v. Stinnie | Date Decided: 2/25/25 | Case No. 23-621
The questions presented in this case are: 1. Whether a party must obtain a ruling that conclusively decides the merits in its favor, as opposed to merely predicting a likelihood of later success, to prevail on the merits under 42 U.S.C. § 1988. 2. Whether a party must obtain an enduring change in the parties' legal relationship from a judicial act, as opposed to a non-judicial event that moots the case, to prevail under 42 U.S.C. § 1988.
The Supreme Court held: The plaintiff drivers here—who gained only preliminary injunctive relief before this action became moot—do not qualify as “prevailing part[ies]” eligible for attorney’s fees under §1988(b) because no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties.
Transcript
Stinney, case number 23 621.
Speaker A:The questions presented in this case 1.
Speaker A: USC section: Speaker A: USC Section: Speaker A:Chief Justice Roberts delivered the opinion of the Court in which Justices Thomas Alito, Kagan, Gorsuch, Kavanaugh, and Barrett joined.
Speaker A:Justice Jackson filed a dissenting opinion in which Justice Sotomayor joined.
Speaker A:Please note that this summary is read by an automated voice.
Speaker B: USC Section: Speaker B:The district court granted a preliminary injunction prohibiting the commissioner from enforcing the statute before trial.
Speaker B:The Virginia General assembly repealed the statute and required reinstatement of licenses suspended under the law.
Speaker B:The parties then agreed to dismiss the pending case as moot.
Speaker B: Section: Speaker B:The district court declined to award attorneys fees to the drivers under that section on the ground that parties who obtain a preliminary injunction do not qualify as prevailing parties.
Speaker B:A Fourth Circuit panel affirmed, but the Fourth Circuit reversed en banc.
Speaker B:The en banc court held that some preliminary injunctions can provide lasting merits based relief and qualify plaintiffs as prevailing parties even if the case becomes moot before final judgment held.
Speaker B: attorneys fees under section: Speaker B:Pages 4 to 13A.
Speaker B:Under the American Rule, a prevailing litigant is ordinarily not entitled to collect attorneys fees from the loser absent express statutory authorization.
Speaker B:CL Yesca Pipeline Service COV.
Speaker B:Wilderness Society 421 U.S.
Speaker B: USC Section: Speaker B:1988b.
Speaker B: vailing parties under section: Speaker B:The court has recognized prevailing party as a legal term of art.
Speaker B:Buchanan Board and Care Home, NKV West Virginia, Deptford of Health and Human Resources, 532 U.S.
Speaker B:598, 603.
Speaker B: When Section: Speaker B: See Black's Law Dictionary,: Speaker B:Preliminary injunctions do not make a party prevailing because they do not conclusively decide the case on the merits.
Speaker B:Such injunctions only determine if a plaintiff is likely to succeed along with factors such as irreparable harm, the balance of equities, and the public interest.
Speaker B:See Winter Verse Natural Resources Defense Counsel, Inc.
Speaker B:555U.S.
Speaker B:7, 20 the purpose of a preliminary injunction is to preserve the status quo until a trial can occur.
Speaker B:See University of Texdive Cheminish, 451U.S.
Speaker B:390, 395 and external events that render a dispute moot do not convert that temporary order into a conclusive adjudication.
Speaker B:Pages 4 to 7b.
Speaker B: ecedence interpreting section: Speaker B:Two recent decisions emphasize that this change must be both judicially sanctioned and enduring.
Speaker B: attorneys fees under section: Speaker B:532 U.S.
Speaker B:at 601.
Speaker B:The court explained that the plaintiff was not a prevailing party because there had been no judicially sanctioned change in the legal relationship of the parties at 605.
Speaker B:And in Seoul v.
Speaker B:Weiner, 551.
Speaker B: within the meaning of section: Speaker B:86 the court's holding in this case that the enduring nature of that change must itself be judicially sanctioned follows naturally from Sol and Buck Hanon.
Speaker B:A plaintiff who wins a transient victory on a preliminary injunction does not become a prevailing party simply because external events convert the transient victory into a lasting one.
Speaker B:Pages 7 to 9 see the Rule established Serves the Interests of Judicial Economy A straightforward bright line rule is easy to administer, reducing the risk of significant litigation over attorneys fees.
Speaker B:Concerns that government defendants who have lost at the preliminary injunction stage will strategically moot litigation are speculative, and such a risk could arise in only a small number of contexts.
Speaker B:The judicial role here is limited.
Speaker B:Congress may amend the statutory language to empower courts to award attorneys fees to plaintiffs who have enjoyed some success but have not prevailed in a judgment on the merits.
Speaker B:Pages 10 to 11D.
Speaker B: ive the argument that section: Speaker B: ongoing suggests that section: Speaker B:But the court's decisions simply indicate that attorneys fees may be awarded when conclusive, enduring judicial relief is meted out on an incremental basis.
Speaker B:Finally, the availability of fees after a court ordered consent decree is consistent with the rule announced here.
Speaker B:While the decree reflects the party's own resolution of the merits, it is approved and given force of law by a court, and it may grant enduring relief that materially alters the legal relationship between the parties.
Speaker B:The dissent conflates preliminary judicial relief that becomes irreversible by way of mootness with relief that is permanent by virtue of a judicial order.
Speaker B: Pages: Speaker A:Congress has authorized courts to award attorneys fees to the prevailing party in certain civil rights cases.
Speaker A:42 U.S.C.
Speaker A: section: Speaker A:Today the court holds that a plaintiff who secures a preliminary injunction does not prevail under this fee shifting statute even when the preliminary injunction provides meaningful relief and is never reversed on the merits.
Speaker A:The court maintains that this holding follows naturally from our precedents at nine.
Speaker A:But that will come as a surprise to the 11 courts of appeals that have previously considered this issue.
Speaker A: fee eligibility under section: Speaker A:By stated simply, the majority's categorical preclusion of fee awards for any plaintiff who successfully obtains preliminary injunctive relief is unwarranted.
Speaker A: basis in the text of section: Speaker A:The court has now eliminated fee eligibility for all preliminary injunctions, even those that effectively resolved the case.
Speaker A:But if Congress had meant for prevailing party status to hinge entirely on the conclusive nature of a judicial order, it could easily have said so.
Speaker A:It is the role of Congress, not this Court, to weigh concerns about administrative ease against the benefits of guaranteeing individuals an opportunity to vindicate their civil rights.
Speaker B:There is no persuasive reason to believe that Congress meant to preclude fee awards for every plaintiff who secures preliminary injunctive relief, but but not a final judgment, no matter the context.
Speaker B:Therefore, I respectfully dissent.
Speaker A:Case Implications Civil rights attorneys may be significantly less willing to represent plaintiffs seeking preliminary injunctive relief if they cannot recover fees when cases become moot before final judgment, potentially reducing access to justice for vulnerable populations.
Speaker A:State and local governments might be incentivized to strategically moot cases after preliminary injunctions are granted to avoid paying attorneys fees, which could become a common practice.
Speaker A:Following this decision, public interest organizations with limited resources might need to be more selective about which civil rights cases they pursue, potentially prioritizing cases seeking damages over those seeking only injunctive relief.
Speaker A: mpt Congress to amend section: