Supreme Court of the United States
Lefemine, Dba Columbia Christians for Life v. Wideman
November 5, 2012568 U.S. 1
Summary
The Supreme Court held that a plaintiff who obtains a permanent injunction that materially alters the defendant’s behavior is a "prevailing party" for purposes of an attorney’s‑fees award under 42 U.S.C. §1988. Accordingly, the Court vacated the Fourth Circuit’s decision that denied fees and remanded for further proceedings. The Court noted that it did not address whether any special circumstances would preclude an award.
Holding
- Whether a plaintiff who obtains only a permanent injunction, without monetary damages, qualifies as a "prevailing party" for attorney’s‑fees purposes under 42 U.S.C. §1988.. Yes; an injunction that materially alters the legal relationship between the parties satisfies the prevailing‑party requirement for an award of attorney’s fees under §1988.
Docket 12-168
Cited authorities
- 42 U.S.C. § 1988
- 42 U.S.C. § 1983
- 90 Stat. 2641
- 42 U.S.C. § 1988