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Keywords

plaintifflitigationattorneyappealdiscriminationclass actioncivil rightsrespondent
plaintiffattorneyinjunctionappealdiscriminationclass actioncivil rightsrespondent

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Newman v. Piggie Park Enterprises, Inc., 390 U.S. 400, 88 S.Ct. 964, 19 L.Ed.2d 1263, 1 Empl. Prac. Dec. P 9834

Facts

The petitioners filed a class action under Title II of the Civil Rights Act of 1964 to address racial discrimination at five drive-in restaurants and a sandwich shop owned by the respondents in South Carolina. The District Court found that the operation of the restaurants affected commerce and that discrimination against Negroes occurred at all six locations. However, it mistakenly concluded that Title II did not apply to the drive-in restaurants, only enjoining discrimination at the sandwich shop.

The petitioners instituted this class action under Title II of the Civil Rights Act of 1964, s 204(a), 78 Stat. 244, 42 U.S.C. s 2000a—3(a), to enjoin racial discrimination at five drive-in restaurants and a sandwich shop owned and operated by the respondents in South Carolina.

Issue

Whether the District Court's refusal to enjoin discrimination at the drive-in restaurants was correct and whether the prevailing party is entitled to reasonable attorney's fees under Title II of the Civil Rights Act of 1964.

Whether the District Court's refusal to enjoin discrimination at the drive-in restaurants was correct and whether the prevailing party is entitled to reasonable attorney's fees under Title II of the Civil Rights Act of 1964.

Rule

Under Title II of the Civil Rights Act of 1964, the prevailing party is entitled to a reasonable attorney's fee as part of the costs, unless special circumstances render such an award unjust.

In any action commenced pursuant to this subchapter, the court, in its discretion, may allow the prevailing party, other than the United States, a reasonable attorney's fee as part of the costs.

Analysis

The Supreme Court analyzed the purpose of the counsel-fee provision in the Civil Rights Act, emphasizing that successful plaintiffs should ordinarily recover attorney's fees to encourage private litigation for enforcing civil rights. The Court found that the District Court's previous conclusion was erroneous and that the respondents' defenses were frivolous, warranting an award of counsel fees.

It follows that one who succeeds in obtaining an injunction under that Title should ordinarily recover an attorney's fee unless special circumstances would render such an award unjust.

Conclusion

The Supreme Court affirmed the judgment of the Court of Appeals, holding that the District Court should include reasonable counsel fees as part of the costs to be assessed against the respondents.

As so modified, the judgment of the Court of Appeals is Affirmed.

Who won?

The petitioners prevailed in the case because the Supreme Court found that they were entitled to reasonable counsel fees due to the frivolous nature of the respondents' defenses.

The Supreme Court ultimately held that prevailing plaintiffs were entitled, in absence of any special circumstances, to have reasonable counsel fees included as part of costs to be assessed against respondents.

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