Lackey v. Stinnie (No. 23-621)
Summary
The Supreme Court case Lackey v. Stinnie (No. 23-621) addresses whether plaintiffs who obtain a preliminary injunction, but whose case becomes moot before a final judgment, qualify as "prevailing parties" eligible for attorney's fees under 42 U.S.C. §1988(b). The Court held that such plaintiffs do not qualify because a preliminary injunction does not constitute a conclusive resolution on the merits. The ruling emphasizes that attorney's fees are only awarded when a court grants enduring judicial relief that materially alters the legal relationship between the parties.
Expected Effects
This decision narrows the circumstances under which plaintiffs can recover attorney's fees in civil rights cases. It means that securing a preliminary injunction, even if it provides significant temporary relief, is insufficient to trigger fee eligibility if the case is later mooted. This may discourage attorneys from taking on cases where only injunctive relief is sought and the possibility of mootness is high.
Potential Benefits
- Provides a clear, bright-line rule for determining prevailing party status, potentially reducing litigation over attorney's fees.
- May discourage strategic behavior by plaintiffs seeking attorney fees without fully litigating the merits.
- Reinforces the principle that attorney's fees are generally awarded only after a conclusive determination on the merits.
- Upholds the American Rule that each party bears its own legal expenses unless a statute explicitly provides otherwise.
- May reduce the number of frivolous lawsuits filed primarily to obtain attorney's fees.
Most Benefited Areas:
Potential Disadvantages
- May discourage attorneys from taking on civil rights cases where the primary goal is injunctive relief, especially if the defendant is likely to moot the case before final judgment.
- Could disproportionately affect plaintiffs with limited resources who rely on attorney's fees to pursue civil rights claims.
- May incentivize government defendants to strategically moot litigation after losing at the preliminary injunction stage to avoid paying attorney's fees.
- Could lead to unfair outcomes where plaintiffs achieve significant temporary relief but are unable to recover attorney's fees due to mootness.
- May complicate civil rights enforcement by making it more difficult for plaintiffs to find legal representation in certain cases.
Most Disadvantaged Areas:
Constitutional Alignment
The ruling is grounded in the Court's interpretation of 42 U.S.C. §1988(b), a statute enacted by Congress under its power to enforce civil rights. The decision itself does not directly implicate any specific constitutional provision. However, the ruling's impact on access to justice and the enforcement of constitutional rights could be viewed through the lens of the Due Process Clause of the Fifth and Fourteenth Amendments, which guarantee fair treatment under the law.
Impact Assessment: Things You Care About ⓘ
This action has been evaluated across 19 key areas that matter to you. Scores range from 1 (highly disadvantageous) to 5 (highly beneficial).