Melene James sued the City of Boise and other defendants in Idaho state court in a 42 U.S.C. § 1983 action, alleging assault, battery, false arrest, wrongful imprisonment and other claims against city police officers, but failed to prevail. In § 1983 suits, federal law provides that the court may “allow the prevailing party, other than the United States, a reasonable attorney’s fee,” but only if it is determined after a hearing that “the plaintiff’s action was frivolous, unreasonable, or without foundation.”
On review, the Idaho Supreme Court chose to disregard that provision of law when deciding to award fees to the defendants. That decision was reversed by the U.S. Supreme Court on January 25, 2016.
In its ruling, the Idaho Supreme Court reasoned that “[a]lthough the Supreme Court may have the authority to limit the discretion of lower federal courts, it does not have the authority to limit the discretion of state courts where such limitation is not contained in the statute.” The state Supreme Court awarded attorney fees under 42 U.S.C. § 1988 even though it held no hearing to determine whether or not the suit filed by James was frivolous. See: James v. City of Boise, 158 Idaho 713 (Idaho 2015).
The problem with the Idaho court’s decision, of course, is that the rule of federal supremacy provides that states must defer to federal court decisions when a federal law, such as § 1988, is being applied. “It is this Court’s responsibility to say what a [federal] statute means, and once the Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law,” the U.S. Supreme Court wrote, citing Nitro-Lift Technologies, L.L.C. v. Howard, 133 S.Ct. 500 (2012) (per curiam).
“The state court erred in concluding otherwise,” the Supreme Court held; the case was reversed and remanded for further proceedings. See: James v. City of Boise, 136 S.Ct. 685 (2016).
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Related legal cases
James v. City of Boise,
|Cite||136 S.Ct. 685 (2016)|
James v. City of Boise
|Cite||158 Idaho 713 (Idaho 2015)|
|Level||State Supreme Court|