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U.S. Supreme Court Defines Prevailing Party for § 1988 Purposes
U.S. Supreme Court Defines Prevailing Party for § 1988 Purposes
The U.S. Supreme Court held that the touchstone of the prevailing party inquiry must be the material alteration of the legal relationship of the parties in a manner that Congress sought to promote in the fee statute. This action was brought by Texas’ Garland Education Association, alleging that school policies infringed upon Teachers’ rights to engage in speech and activities related to employee organization and union activities.
The action resulted in materially altering the school district’s policy limiting the teachers’ rights, but also resulted in the teachers losing on several issues. See: Texas State Teachers Association v. Garland Independent School District, 777 F.2d 1046 (1985), cert denied; 479 U.S. 801, 107 S.Ct. 41, 93 (Ed. 2d 4 (1986)). The teachers then moved for an award of attorneys’ fees as the prevailing party. The Texas District Court recognized the teachers achieved “partial success,” but indicated that “in this circuit the test for prevailing party status is whether the plaintiff prevailed on the central issue by acquiring the primary relief.” The court held the teachers did not prevail on the central issue and denied an attorney fee award. The court of Appeals affirmed. See: 837 F. 2d 190 (1988).
The Supreme Court said, “the search for ‘central’ and ‘tangential’ issues in the lawsuit, or for the ‘primary,’ as opposed to the ‘secondary,’ relief sought, much like the search for the golden fleece, distracts the district court from the primary purposes behind [42 U.S.C.] D1988 and is essentially unhelpful in defining the term prevailing party.”
The Court held the plaintiff is prevailing party if there is “success” on “any significant issue in litigation which achieved some of the benefit the parties sought in bringing the suit.” At a minimum, the plaintiff must be able to point to a resolution of the dispute that changes the legal relationship between itself and the defendant. If a plaintiff’s success on a legal claim can be characterized as purely technical or de minimus, a district court would be justified in concluding the “generous formulation” has not been satisfied. The Court held the teachers were prevailing parties and reversed the lower courts’ judgment. See: Texas State Teachers Association v. Garland Independent School District, 489 U.S. 782, 109 S. Ct. 1486, 103 (Ed. 2d 866 (1988)).
The U.S. Supreme Court held that the touchstone of the prevailing party inquiry must be the material alteration of the legal relationship of the parties in a manner that Congress sought to promote in the fee statute. This action was brought by Texas’ Garland Education Association, alleging that school policies infringed upon Teachers’ rights to engage in speech and activities related to employee organization and union activities.
The action resulted in materially altering the school district’s policy limiting the teachers’ rights, but also resulted in the teachers losing on several issues. See: Texas State Teachers Association v. Garland Independent School District, 777 F.2d 1046 (1985), cert denied; 479 U.S. 801, 107 S.Ct. 41, 93 (Ed. 2d 4 (1986)). The teachers then moved for an award of attorneys’ fees as the prevailing party. The Texas District Court recognized the teachers achieved “partial success,” but indicated that “in this circuit the test for prevailing party status is whether the plaintiff prevailed on the central issue by acquiring the primary relief.” The court held the teachers did not prevail on the central issue and denied an attorney fee award. The court of Appeals affirmed. See: 837 F. 2d 190 (1988).
The Supreme Court said, “the search for ‘central’ and ‘tangential’ issues in the lawsuit, or for the ‘primary,’ as opposed to the ‘secondary,’ relief sought, much like the search for the golden fleece, distracts the district court from the primary purposes behind [42 U.S.C.] D1988 and is essentially unhelpful in defining the term prevailing party.”
The Court held the plaintiff is prevailing party if there is “success” on “any significant issue in litigation which achieved some of the benefit the parties sought in bringing the suit.” At a minimum, the plaintiff must be able to point to a resolution of the dispute that changes the legal relationship between itself and the defendant. If a plaintiff’s success on a legal claim can be characterized as purely technical or de minimus, a district court would be justified in concluding the “generous formulation” has not been satisfied. The Court held the teachers were prevailing parties and reversed the lower courts’ judgment. See: Texas State Teachers Association v. Garland Independent School District, 489 U.S. 782, 109 S. Ct. 1486, 103 (Ed. 2d 866 (1988)).
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Related legal case
Texas State Teachers Association v. Garland Independent School District
| Year | 1988 |
|---|---|
| Cite | 489 U.S. 782, 109 S. Ct. 1486, 103 (Ed. 2d 866 (1988)) |
| Level | Supreme Court |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |