Tex. State Teachers Ass'n v. Garland Indep. Sch. Dist.

Tex. State Teachers Ass'n v. Garland Indep. Sch. Dist.

Opinion

 [*784]   [***872]   [**1489]  JUSTICE O'CONNOR delivered the opinion of the Court.

 [****6]    We must decide today the proper standard for determining whether a party has "prevailed" in an action brought under certain civil rights statutes such that the party is eligible for an award of attorney's fees under the Civil Rights Attorney's Fees Awards Act of 1976, 90 Stat. 2641, 42 U. S. C. § 1988. This is an issue which has divided the Courts of Appeals both before and after our decision in Hensley v. Eckerhart, 461 U.S. 424 (1983). The Courts of Appeals for the Fifth and Eleventh Circuits require that a party succeed on the "central issue" in the litigation and achieve the "primary relief sought" to be eligible for an award of attorney's fees under § 1988.  See, e.g., Simien v. San Antonio, 809 F. 2d 255, 258 (CA5 1987); Martin v. Heckler, 773 F. 2d 1145, 1149 (CA11 1985) (en banc).  Most of the other Federal Courts of Appeals have applied a less demanding standard, requiring only that a party succeed on a significant issue and receive some of the [****7]  relief sought in the lawsuit to qualify for a fee award. See, e.g., Gingras v. Lloyd, 740 F. 2d 210, 212 (CA2 1984); Lampher v. Zagel, 755 F. 2d 99, 102 (CA7 1985); Fast v. School Dist. of Ladue, 728 F. 2d 1030, 1032-1033 (CA8 1984) (en banc); Lummi Indian Tribe v. Oltman, 720 F. 2d 1124, 1125 (CA9 1983); Nephew v. Aurora, 766 F. 2d 1464, 1466 (CA10 1985). In this case, the Court of Appeals for the Fifth Circuit applied the "central issue" test and concluded that petitioners here were not prevailing parties under § 1988. Because of the conflicting views in the Courts of Appeals, and because of the importance of the definition of the term "prevailing party" to the application of § 1988 and other federal fee shifting statutes, we granted certiorari. 488 U.S. 815 (1988).

 [*785]  I

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