CRST Van Expedited, Inc. v. Equal Emp't Opportunity Comm'n
136 S. Ct. 1642
SCOTUS2016Background
- CRST Van Expedited (CRST) faced a multi-year EEOC enforcement action alleging sexual harassment by trainers, based on Monika Starke's charge and many additional alleged victims.
- The EEOC investigated, found reasonable cause, attempted conciliation, then sued under Title VII §706 seeking injunctive relief and damages on behalf of a group of aggrieved women.
- The District Court dismissed a presumed §707 pattern-or-practice claim and later dismissed claims for most alleged victims (including 67 claims) on various grounds, including that the EEOC failed to satisfy Title VII’s presuit investigation/conciliation requirements; the court awarded CRST over $4 million in attorney’s fees.
- The Eighth Circuit affirmed many dismissals but held CRST was not a "prevailing party" entitled to fees for claims dismissed for failure to satisfy presuit requirements because, under its precedent, a defendant must obtain a judicial ruling on the merits to be "prevailing." It vacated the fee award and remanded for particularized findings.
- The Supreme Court granted certiorari and held that a favorable merits ruling is not a necessary predicate for a defendant to be a "prevailing party" under Title VII; defendants can prevail when the plaintiff’s challenge is rebuffed for nonmerits reasons as well.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Definition of "prevailing party" for Title VII fee awards | EEOC: no strict on-the-merits requirement; prevailing should be assessed without formal merits test | CRST: a defendant should be a prevailing party when litigation ends in the defendant's favor (including nonmerits dismissals) | Court: A favorable merits ruling is not required; a defendant can prevail when the plaintiff’s challenge is rebuffed, merits or not |
| Whether Title VII presuit failures are nonmerits and preclude fee recovery | EEOC: presuit requirements are not jurisdictional elements; dismissal for failing them is nonmerits and should not automatically make defendant prevailing | CRST: dismissals for failure to investigate/conciliate can be dispositive and justify prevailing-party status and fees | Court: Declined to adopt a categorical preclusion/preclusive-judgment rule here; left factual and preclusion questions to lower courts to decide in first instance |
| Standard to award fees to prevailing defendant | EEOC: even if prevailing, fees inappropriate if EEOC’s position was not frivolous or unreasonable | CRST: fees appropriate where EEOC unreasonably failed to investigate/conciliate or pursued frivolous claims | Court: Reaffirmed Christiansburg standard — defendant may get fees when plaintiff’s claim was frivolous, unreasonable, or groundless; lower courts should apply that standard on remand |
Key Cases Cited
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Resources, 532 U.S. 598 (judicial imprimatur required for prevailing party in some contexts)
- Texas State Teachers Assn. v. Garland Indep. Sch. Dist., 489 U.S. 782 (prevailing party inquiry concerns material alteration of legal relationship)
- Hensley v. Eckerhart, 461 U.S. 424 (fee award standards and reasonableness)
- Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (standard for awarding fees to prevailing defendants: frivolous, unreasonable, or groundless suits)
- Fox v. Vice, 563 U.S. 826 (prevailing-party fee principles and allocation when claims are mixed)
- Gen. Tel. Co. of Northwest v. EEOC, 446 U.S. 318 (§706 EEOC actions and class/group relief procedures)
- Mach Mining, LLC v. EEOC, 575 U.S. (discussion of EEOC’s enforcement procedures under Title VII)