Lisa Romain v. Marketa Walters, 2017 U.S. App. LEXIS 8162

Seven Louisiana SNAP recipients challenged the state Department of Children & Family Services after a statewide SNAP "work requirement" waiver expired on Sept. 30, 2015, exposing ~62,000 recipients to the work requirement and notices of benefit termination.
Plaintiffs filed suit (Dec. 18, 2015) seeking declaratory and injunctive relief under due process principles and 7 U.S.C. § 2015(o), and requested attorneys' fees under 42 U.S.C. § 1988; they also moved for class certification and emergency relief.
The parties submitted a settlement order (signed Jan. 19, 2016) that conditioned dismissal on the USDA granting a statewide waiver and required the State to (1) ensure January 2016 SNAP benefits issued by Jan. 22, 2016, (2) prevent the three-month sanction period from starting for class members, and (3) issue new notice to affected recipients.
Governor-elect Edwards subsequently sought and obtained the waiver and the settlement conditions were met, leading to dismissal of the suit.
Plaintiffs moved for $136,253.25 in fees and $1,888.57 in costs; the district court denied the fee request, finding Plaintiffs were not "prevailing parties," prompting this appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Were Plaintiffs "prevailing parties" under § 1988?	Settlement order is judicially‑sanctioned relief that altered legal relations and changed defendant behavior, so Plaintiffs prevailed.	The relief flowed from voluntary executive/political action (Governor‑elect), not from the lawsuit; thus Plaintiffs did not prevail.	Plaintiffs are prevailing parties as a matter of law (consent decree materially altered legal relationship and modified defendant behavior).
Do "special circumstances" permit denying fees despite prevailing‑party status?	No special circumstances existed; denial would be improper absent strong proof.	The State asserted that plaintiffs' litigation did not contribute to the waiver and that the Governor's independent actions justify denial.	Remanded: district court must assess evidence of special circumstances; defense bears burden and must make an "extremely strong showing."
If no special circumstances, must fees be awarded?	If prevailing and no special circumstances, fees are mandatory.	N/A (defense sought to avoid fee obligation via prevailing‑party and special‑circumstances arguments).	If no special circumstances found, district court must calculate reasonable and necessary fees on remand.
Standard of review for prevailing‑party determination and fee denial?	N/A (positions implicit).	N/A	Prevailing‑party status: de novo; denial of § 1988 fees: abuse of discretion; factual findings: clear error.

Martin v. Halliburton, 618 F.3d 476 (5th Cir.) (defining when litigation ends for appellate jurisdiction)
Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (2001) (consent decrees can create prevailing‑party status by materially altering legal relations)
Lefemine v. Wideman, 133 S. Ct. 9 (2012) (plaintiff prevails when relief on the merits materially alters legal relations and modifies defendant behavior)
Petteway v. Henry, 738 F.3d 132 (5th Cir.) (three‑part test for prevailing‑party under § 1988)
Sanchez v. City of Austin, 774 F.3d 873 (5th Cir.) (prevailing plaintiffs ordinarily recover fees absent special circumstances)
Hensley v. Eckerhart, 461 U.S. 424 (1983) (standards for awarding attorney's fees)
Farrar v. Hobby, 506 U.S. 103 (1992) (definition of prevailing party and relief that warrants fees)
Grisham v. City of Fort Worth, 837 F.3d 564 (5th Cir.) (discussing narrow "did‑not‑contribute" special‑circumstance exception)
Pruett v. Harris Cty. Bail Bond Bd., 499 F.3d 403 (5th Cir.) (defendant must make a strong showing to invoke special circumstances to deny fees)