604 U.S. 192
U.S.2025Background
- Virginia drivers had their licenses suspended under a state statute for failure to pay court fines and costs.
- The drivers sued the Commissioner of the Virginia Department of Motor Vehicles under 42 U.S.C. § 1983, challenging the statute as unconstitutional.
- The District Court issued a preliminary injunction prohibiting enforcement of the statute, finding drivers likely to succeed on the merits.
- Before a final judgment, the Virginia legislature repealed the law and reinstated licenses, making the lawsuit moot and resulting in stipulated dismissal.
- The key dispute became whether the plaintiffs, who only obtained preliminary injunctive relief before mootness, could be considered “prevailing parties” eligible for attorney’s fees under §1988(b).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does obtaining only a preliminary injunction, without a final judgment on the merits, confer “prevailing party” status under §1988(b)? | Stinnie: Preliminary injunction granted meaningful, merits-based relief and should confer prevailing party status if it functionally resolved the case. | Lackey: Only a conclusive, judicially sanctioned resolution on the merits (not a preliminary injunction) can make a plaintiff a prevailing party. | No; preliminary injunctions, which do not conclusively resolve the merits, do not make a party "prevailing" under §1988(b), even if the case becomes moot. |
| Should the court’s legal standard depend on whether lasting relief was achieved via the preliminary injunction? | Stinnie: Some preliminary injunctions provide lasting and concrete relief, similar to summary judgment or consent decrees. | Lackey: The relief must be both judicially sanctioned and enduring, and preliminary injunctions are by nature temporary and interlocutory. | The change in the legal relationship must be judicially sanctioned and enduring; preliminary injunctions are by nature temporary and insufficient. |
| Does policy or legislative history support allowing interim victories to qualify for attorney’s fees? | Stinnie: Fee-shifting in civil rights suits should be broadly available to encourage enforcement, especially where plaintiffs succeed in practice. | Lackey: The "American Rule" and statutory text require a strict approach, with Congress having the power to alter the standard if desired. | Statute requires a final, judicial, merits-based decision; concerns about judicial economy and congressional intent do not alter the outcome. |
| Can external events (like legislative repeal) which moot the case make an interim preliminary injunction into enduring, fee-eligible relief? | Stinnie: If external events prevent further adjudication, unreversed preliminary injunctions should count as prevailing. | Lackey: External events do not convert temporary orders into permanent, judicially-sanctioned resolutions. | No, mootness due to external events does not transform preliminary relief into prevailing party status. |
Key Cases Cited
- Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep't of Health & Human Res., 532 U.S. 598 (U.S. 2001) (Judicially-sanctioned change, not voluntary change, required for prevailing party status)
- Sole v. Wyner, 551 U.S. 74 (U.S. 2007) (Preliminary injunctions superseded by adverse final ruling do not confer prevailing party status)
- Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240 (U.S. 1975) (American Rule: fees not shifted without express statutory grant)
- Texas State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782 (U.S. 1989) (Material alteration of the legal relationship is required to prevail)
- Farrar v. Hobby, 506 U.S. 103 (U.S. 1992) (Nominal damages can confer prevailing party status if legal relationship is altered)