James v. City of Boise

136 S. Ct. 685 (2016)

 

RULE:

The Idaho Supreme Court, like any other state or federal court, is bound by this Court’s interpretation of federal law.

FACTS:

The matter involves the interpretation on when attorney’s fees may be recovered by the prevailing party. Under federal law, a court has discretion to “allow the prevailing party, other than the United States, a reason-able attorney’s fee” in a civil rights lawsuit filed under 42 U. S. C. §1983, 42 U. S. C. §1988. The case of Hughes v. Rowe, 449 U. S. 5, 101 S. Ct. 173, 66 L. Ed. 2d 163 (1980) limited recovery of attorney’s fees only if the plaintiff’s action was frivolous, unreasonable or without foundation. The Idaho Supreme Court, however, concluded that it was not bound by the interpretation in the Hughes case since the United States Supreme Court does not have the authority to limit the discretion of state courts where such limitation is not contained in the statute. Accordingly, the Idaho Supreme Court awarded attorney’s fees without determining if the action was frivolous, unreasonable or without foundation.

ISSUE:

Is the Idaho Supreme Court bound by the interpretation of federal law by the United States Supreme Court?

ANSWER:

Yes.

CONCLUSION:

The Idaho Supreme Court, like any other state or federal court, is bound by this Court’s interpretation of federal law. Otherwise, if state courts were permitted to disregard the court’s ruling on federal law, then the laws, the treaties and the constitution of the United States would be different in different states.  The state court erred in concluding otherwise.

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