The U.S. Supreme Court ruled on Tuesday that a group of Virginia drivers, who challenged a state motor vehicle law and initially succeeded with a preliminary injunction, were not entitled to attorney’s fees reimbursement. The decision, with a 7-2 vote, determined that the drivers were not “prevailing parties” under the federal law which allows for such reimbursement in certain civil rights cases. The federal district court had temporarily barred the enforcement of the Virginia law regarding driver’s license suspensions for unpaid fines. However, the subsequent legislative repeal of the law rendered the case moot, resulting in the case’s dismissal.
The ruling was penned by Chief Justice John Roberts. The dissent came from Justice Ketanji Brown Jackson, joined by Justice Sonia Sotomayor. The precedent discussion emphasized the distinction between temporary and enduring victories in the legal process. Roberts’s opinion pointed out that a preliminary injunction, which provides temporary relief, does not equate to a prevailing party status, even if external conditions resolve the dispute in favor of the plaintiff. This stance aligns with previous decisions, including Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health and Human Resources and Sole v. Wyner, which assert that changes in legal relationships must be judicially sanctioned to merit attorney’s fees.
This decision could have long-term impacts on civil rights litigation strategy. While Roberts maintained that the decision would simplify fee debates, Jackson voiced concerns that it could discourage attorneys from undertaking civil rights cases. Jackson highlighted that all 11 federal appellate courts to consider the issue previously agreed on awarding attorney’s fees for some preliminary injunctions, arguing that the new ruling departs from established understandings and could undermine statutory aims of encouraging civil rights litigation.
To read more about the ruling and its implications, see the full article on SCOTUSblog.