Lefemine v. Wideman, 133 S. Ct. 9

Lefemine and Columbia Christians for Life conducted graphic-protest demonstrations; County police warned to stop or face sanctions.
A letter threatened further sanctions; fear led the group to suspend protests for two years.
Lefemine filed a 42 U.S.C. §1983 suit alleging First Amendment violations, seeking injunctive relief, nominal damages, and fees.
District Court found violations, issued a permanent injunction prohibiting content-based restrictions on signs but denied nominal damages and attorney’s fees.
Fourth Circuit affirmed denial of fees, holding Lefemine was not a prevailing party under §1988 because relief did not alter the parties’ relative positions.
Supreme Court granted certiorari, vacated the Fourth Circuit, and remanded to consider whether Lefemine qualified as a prevailing party under established standards.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Lefemine was a prevailing party under §1988.	Lefemine’s injunction altered defendants’ behavior benefitting him.	No monetary damages; relief did not alter relative positions sufficiently.	Yes; Lefemine prevailed; injunction changed behavior and benefited him.
Whether an injunction alone can satisfy the prevailing party standard.	Injunctive relief often suffices to establish prevailing party status.	Injunctions insufficient without monetary relief or broader relief.	Injunctions can satisfy the standard when they materially alter the legal relationship to the plaintiff’s benefit.

Farrar v. Hobby, 506 U.S. 103 (1992) (prevailing party when relief alters the legal relationship and benefits the plaintiff)
Rhodes v. Stewart, 488 U.S. 1 (1988) (injunctions/declaratory judgments can satisfy prevailing party test)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (fee-shifting requires prevailing party status absent unjust circumstances)