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Lackey v. Stinnie

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Supreme Court of the United States
Lackey v. Stinnie
Term: 2024
Important Dates
Argued: October 8, 2024
Outcome
reversed and remanded
Vote
7-2
Majority
Chief Justice John Roberts • Clarence Thomas • Samuel Alito • Elena Kagan • Neil Gorsuch • Brett Kavanaugh • Amy Coney Barrett
Dissenting
Sonia Sotomayor • Ketanji Brown Jackson

Lackey v. Stinnie is a case that was decided by the Supreme Court of the United States on February 25, 2025, during the court's October 2024-2025 term. The case argued before the Supreme Court of the United States on October 8, 2024.

In a 7-2 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit, holding that the plaintiff drivers in this case do not qualify as prevailing parties eligible for attorney’s fees under §1988(b) because no court conclusively resolved their claims by granting enduring judicial relief for reasons that materially altered the legal relationship between the parties. Chief Justice John Roberts delivered the opinion of the court.[1]

HIGHLIGHTS
  • The issue: The case concerned the standard necessary to qualify as a prevailing party in a case in order to be awarded attorney’s fees. Click here to learn more about the case's background.
  • The questions presented: "1. Whether a party must obtain a ruling that conclusively decides the merits in its favor, as opposed to merely predicting a likelihood of later success, to prevail on the merits under 42 U.S.C. § 1988.
    2. Whether a party must obtain an enduring change in the parties' legal relationship from a judicial act, as opposed to a non-judicial event that moots the case, to prevail under 42 U.S.C. § 1988."[2]
  • The outcome: In a 7-2 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit.


    • The case came on a writ of certiorari to the United States Court of Appeals for the Fourth Circuit. To review the lower court's opinion, click here.

    Background

    Case summary

    The following are the parties to this case:[3]

    • Petitioner: Gerald F. Lackey, in His Official Capacity as the Commissioner of the Virginia Department of Motor Vehicles
    • Respondent: Damian Stinnie, et al.
      • Legal counsel: Brian David Schmalzbach (McGuireWoods LLP), Jonathan T. Blank (McGuireWoods LLP), Matthew Allen Fitzgerald (McGuireWoods LLP)

    The following summary of the case was published by Oyez, a free law project from Cornell’s Legal Information Institute, Justia, and the Chicago-Kent College of Law:[4]

    “

    Under the so-called “American Rule,” each litigant pays their own attorney’s fees, regardless of whether they win or lose. However, certain statutes permit the payment of “a reasonable attorney’s fee” to “the prevailing party” in litigation; 42 U.S.C. § 1988 is one such statute, permitting the payment of attorney’s fees to parties that prevail in civil rights litigation.

    Several indigent Virginia residents challenged in federal court a state statute that required automatic suspension of the driver’s licenses of those who failed to pay certain court fines and fees. Finding the plaintiffs were likely to succeed on the merits of their case, the district court granted a preliminary injunction ordering the state to remove the plaintiffs’ suspensions. The state did not appeal the injunction, so the plaintiffs were able to drive again. Before the case could go to trial, the Virginia legislature repealed the statute. The plaintiffs then petitioned for attorney’s fees under Section 1988, but the district court rejected that request, citing a decision of the U.S. Court of Appeals for the 4th Circuit holding that a grant of a preliminary injunction does not render a plaintiff a “prevailing party.” The plaintiffs appealed. A panel of the U.S. Court of Appeals for the Fourth Circuit affirmed, but, on rehearing, the en banc 4th Circuit reversed.[5]

    		”

    To learn more about this case, see the following:

    Timeline

    The following timeline details key events in this case:

    Questions presented

    The petitioner presented the following questions to the court:[2]

    Questions presented:
    “ 1. Whether a party must obtain a ruling that conclusively decides the merits in its favor, as opposed to merely predicting a likelihood of later success, to prevail on the merits under 42 U.S.C. § 1988.
    2. Whether a party must obtain an enduring change in the parties' legal relationship from a judicial act, as opposed to a non-judicial event that moots the case, to prevail under 42 U.S.C. § 1988.[5]     		”

    Oral argument

    The U.S. Supreme Court heard oral argument on October 8, 2024.

    Audio

    Audio of oral argument:[7]



    Transcript

    Transcript of oral argument:[8]

    Outcome

    In a 7-2 opinion, the court reversed and remanded the judgment of the United States Court of Appeals for the Fourth Circuit, holding that the plaintiff drivers in this case do not qualify as prevailing parties eligible for attorney’s fees under §1988(b) because no court conclusively resolved their claims by granting enduring judicial relief for reasons that materially altered the legal relationship between the parties. Chief Justice John Roberts delivered the opinion of the court.[1]

    Opinion

    In the court's majority opinion, Chief Justice John Roberts wrote:[1]

    “

    Section 1988(b) permits courts to award attorney’s fees to a ‘prevailing party.’ A party ‘prevails’ when a court conclusively resolves his claim by granting enduring relief on the merits that alters the legal relationship between the parties. Critically, both the change in relationship and its permanence must result from a judicial order. A preliminary injunction, which temporarily preserves the parties’ litigating positions based in part on a prediction of the likelihood of success on the merits, does not render a plaintiff a ‘prevailing party.’ Nor do external events that moot the action and prevent the court from conclusively adjudicating the claim. Because the drivers in the present case gained only preliminary injunctive relief before this action became moot, they do not qualify as ‘prevailing part[ies]’ eligible for attorney’s fees under §1988(b). [5]

    		”
    —Chief Justice John Roberts

    Dissenting opinion

    Justice Ketanji Brown Jackson filed a dissenting opinion, joined by Justice Sonia Sotomayor.

    In her dissent, Justice Brown Jackson wrote:[1]

    “

    Congress has authorized courts to award attorney’s fees to the “prevailing party” in certain civil rights cases. 42 U. S. C. §1988(b). Today, the Court holds that a plaintiff who secures a preliminary injunction does not “prevail” under this fee-shifting statute, even when the preliminary injunction provides meaningful relief and is never reversed on the merits. The Court maintains that this holding “follows naturally from” our precedents. Ante, at 9. But that will come as a surprise to the eleven Courts of Appeals that have previously considered this issue; all of them agree that at least some preliminary injunctions trigger fee eligibility under §1988(b).

    Stated simply, the majority’s categorical preclusion of fee awards for any plaintiff who successfully obtains preliminary injunctive relief is unwarranted. It lacks any basis in the text of §1988(b) and is plainly inconsistent with that statutory provision’s clear objective, which is to encourage attorneys to file civil rights actions on behalf of the most vulnerable people in our society. The Court has now eliminated fee eligibility for all preliminary injunctions—even those that effectively resolve the case. But if Congress had meant for “prevailing party” status to hinge entirely on the “conclusive” nature of a judicial order, it could easily have said so. It is the role of Congress, not this Court, to weigh concerns about administrative ease against the benefits of guaranteeing individuals an opportunity to vindicate their civil rights.

    There is no persuasive reason to believe that Congress meant to preclude fee awards for every plaintiff who secures preliminary injunctive relief but not a final judgment, no matter the context. Therefore, I respectfully dissent. [5]

    		”
    —Justice Ketanji Brown Jackson

    Text of the opinion

    Read the full opinion here.

    The URL or file path ILackey v. Stinnie opinion.pdf does not exist.

    October term 2024-2025

    See also: Supreme Court cases, October term 2024-2025

    The Supreme Court began hearing cases for the term on October 7, 2024. The court's yearly term begins on the first Monday in October and lasts until the first Monday in October the following year. The court generally releases the majority of its decisions in mid-June.[9]


    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 U.S. Supreme Court, "Lackey v. Stinnie," February 25, 2025
    2. ↑ 2.0 2.1 U.S. Supreme Court, "23-621 LACKEY V. STINNIE QP REPORT," April 22, 2024
    3. ↑ Supreme Court of the United States, "No. 23-621," accessed August 7, 2024
    4. ↑ Oyez, "Lackey v. Stinnie," accessed August 7, 2024
    5. ↑ 5.0 5.1 5.2 5.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    6. ↑ U.S. Court of Appeals for the Fourth Circuit, Stinnie v. Holcomb, decided August 7, 2023
    7. ↑ Supreme Court of the United States, "Oral Argument - Audio," argued October 8, 2024
    8. ↑ Supreme Court of the United States, "Oral Argument - Transcript," argued October 8, 2024
    9. ↑ SupremeCourt.gov, "The Supreme Court at Work: The Term and Caseload," accessed January 24, 2022
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