![if gte IE 9]><![endif]><![if gte IE 9]><![endif]><![if gte IE 9]><![endif]>
Thank You For Submiting Feedback!
Under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., which prohibits discrimination in employment, a district court may award attorney’s fees to “the prevailing party.” 42 U.S.C.S. § 2000e-5(k). A favorable ruling on the merits is not a necessary predicate to find that a defendant has prevailed.
Petitioner CRST Van Expedited Inc., a trucking company, required its drivers to graduate from the company's training program before becoming a certified driver. In 2005, a new driver named Monika Starke filed a charge with respondent Equal Employment Opportunity Commission, alleging that she was sexually harassed by two male trainers during the road-trip portion of her training. Following the procedures set out in Title VII of the Civil Rights Act of 1964, respondent informed petitioner about the charge and investigated the allegation, ultimately informing the latter that it found reasonable cause to believe that petitioner subjected the female employee and a class of employees and prospective employees to sexual harassment and offered to conciliate. In 2007, having determined that conciliation had failed, respondent, in its own name, filed suit against petitioner under §706 of Title VII. During discovery, respondent identified over 250 allegedly aggrieved women. However, the district court dismissed all of the claims as the court found that they were barred on the ground that respondent had not adequately investigated or attempted to conciliate its claims on their behalf before filing suit. The district court then dismissed the suit, held that petitioner was a prevailing party, and invited petitioner to apply for attorney's fees which it did and was awarded the same. The Eighth Circuit reversed the dismissal of only two claims, on behalf of Starke and one other employee, but that led it to vacate, without prejudice, the attorney's fees award. On remand, respondent settled the claim on behalf of Starke and withdrew the other. Petitioner again sought attorney's fees, and the district court again awarded it, finding that petitioner had prevailed on the claims because of the respondent’s failure to satisfy its pre-suit requirements. The Eighth Circuit reversed and remanded once more. It held that a Title VII defendant can be a prevailing party only by obtaining a ruling on the merits, and that the district court's dismissal of the claims was not.
Did the appellate court correctly hold that a Title VII defendant can be a prevailing party only by obtaining a ruling on the merits?
The Supreme Court vacated the judgment and remanded the case. The court held that in the respondent's suit against petitioner under Title VII of the Civil Rights Act of 1964, 42 U.S.C.S. § 2000e et seq., where the appellate court reversed an award of attorney's fees under 42 U.S.C.S. § 2000e-5(k) and held that petitioner did not prevail on claims brought on behalf of 67 women because the district court’s disposition of these claims for failure to investigate and conciliate was not a ruling on the merits, the appellate court erred by applying an on-the-merits requirement because a defendant need not obtain a favorable judgment on the merits in order to be a prevailing party. Moreover, there was no indication that Congress intended that defendants should be eligible to recover attorney's fees only when courts dispose of claims on the merits. Title VII's fee-shifting statute allowed prevailing defendants to recover whenever the plaintiff's claim was frivolous, unreasonable, or groundless. Case law provided that Congress, thus, must have intended that a defendant could recover fees expended in frivolous, unreasonable, or groundless litigation when the case is resolved in the defendant's favor, whether on the merits or not. However, the Supreme Court declined to decide the Commission's argument that a defendant must obtain a preclusive judgment in order to prevail.