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CRST Van Expedited, Inc. v. EEOC

Supreme Court of the United States

March 28, 2016, Argued; May 19, 2016, Decided

No. 14-1375

Opinion

 [*1646]  [**713]   Justice Kennedy delivered the opinion of the Court.

This case involves the interpretation of a statutory provision allowing district courts to award attorney’s fees to defendants in employment discrimination actions. Under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, as amended, 42 U. S. C. §2000e et seq., which prohibits discrimination in employment, a district court may award attorney’s fees to “the prevailing party.” §2000e-5(k). The Court of Appeals for the Eighth Circuit held that a Title VII defendant prevails only by obtaining a “ruling on the merits.” 774 F. 3d 1169, 1179 (2014); Marquart v. Lodge 837, Machinists and Aerospace Workers, 26 F. 3d 842, 851-852 (1994). This Court disagrees with that conclusion. The Court now holds that a favorable ruling on the merits is not a necessary predicate to find that a defendant has prevailed.

Title VII of the Civil Rights Act of 1964 authorizes an award of attorney’s fees in certain circumstances. The statute provides that

“[i]n any action or proceeding under this subchapter the court, in its discretion, may allow the prevailing party, other than the [Equal [***6]  Employment Opportunity] Commission or the United States, a reasonable attorney’s fee (including expert fees) as part of the costs, and the Commission and the United States shall be liable for costs the same as a private person.” §2000e-5(k).

Before deciding whether an award of attorney’s fees is appropriate in a given case, then, a court must determine whether the party seeking fees has prevailed in the litigation. Texas State Teachers Ass'n v. Garland Independent School Dist., 489 U.S. 782, 789, 109 S. Ct. 1486, 103 L. Ed. 2d 866 (1989); Hensley v. Eckerhart, 461 U. S. 424, 433, 103 S. Ct. 1933, 76 L. Ed. 2d 40 (1983).

Congress has included the term “prevailing party” in various fee-shifting statutes, and it has been the Court’s approach to interpret the term in a consistent manner. See Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep't of Health & Human Res., 532 U. S. 598, 602, 603, and n. 4, 121 S. Ct. 1835, 149 L. Ed. 2d 855 (2001). The Court has said that the “touchstone of the prevailing party inquiry must be the material alteration of the legal relationship of the parties.” Texas State Teachers Assn., supra, at 792-793, 109 S. Ct. 1486, 103 L. Ed. 2d 866. This change must be marked by “judicial imprimatur.” Buckhannon, 532 U. S., at 605, 121 S. Ct. 1835, 149 L. Ed. 2d 855. The Court has explained that, when a plaintiff secures an “enforceable judgmen[t] on the merits” or a “court-ordered consent decre[e],” that plaintiff is the prevailing party because he has received a “judicially sanctioned change in the legal relationship of the parties.” Id., at 604-605, 121 S. Ct. 1835, 149 L. Ed. 2d 855. The Court, however, has not set forth in detail how courts should determine whether a defendant has prevailed.

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136 S. Ct. 1642 *; 194 L. Ed. 2d 707 **; 2016 U.S. LEXIS 3350 ***; 84 U.S.L.W. 4287; 129 Fair Empl. Prac. Cas. (BNA) 134; 100 Empl. Prac. Dec. (CCH) P45,557; 26 Fla. L. Weekly Fed. S 160

CRST VAN EXPEDITED, INC., Petitioner v. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

Notice: The LEXIS pagination of this document is subject to change pending release of the final published version.

Subsequent History: On remand at, Motion denied by, As moot EEOC v. CRST Van Expedited, Inc., 2016 U.S. Dist. LEXIS 141704 (N.D. Iowa, Oct. 13, 2016)

Prior History:  [***1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE EIGHTH CIRCUIT

EEOC v. CRST Van Expedited, Inc., 774 F.3d 1169, 2014 U.S. App. LEXIS 24130 (8th Cir. Iowa, 2014)

Disposition: 774 F. 3d 1169, vacated and remanded.

CORE TERMS

district court, merits, prevail, prevailing party, conciliation, frivolous, pattern-or-practice, presuit, investigate, sexual harassment, marks, quotation, allegations, groundless, cases, aggrieved person, own name, harassment, aggrieved, parties, driver

Labor & Employment Law, Title VII Discrimination, Remedies, Costs & Attorney Fees, Civil Procedure, Attorney Fees & Expenses, Basis of Recovery, Statutory Awards, Business & Corporate Compliance, US Equal Employment Opportunity Commission, Authorities & Powers, Investigative Authority, Civil Actions, Notice to Employers, Reasonable Cause & Conciliation, Special Proceedings, Class Actions, Certification of Classes, Regulators, Civil Actions, Discrimination, Gender & Sex Discrimination, EEOC & State Actions, Employment Practices, Discriminatory Pattern & Practice, Civil Rights Law, Procedural Matters, Costs & Attorney Fees, Prevailing Parties, US Supreme Court Review, Attorney Fees & Expenses