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Keywords

litigationattorneystatuteinjunctionappeal
litigationattorneyappealcommon lawrespondent

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Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240, 95 S.Ct. 1612, 44 L.Ed.2d 141, 10 Fair Empl.Prac.Cas. (BNA) 826, 7 ERC 1849, 11 Empl. Prac. Dec. P 10,842, 5 Envtl. L. Rep. 20,286

Facts

The litigation was initiated by the Wilderness Society, Environmental Defense Fund, Inc., and Friends of the Earth to prevent the issuance of permits required for the construction of the trans-Alaska oil pipeline. The District Court granted a preliminary injunction against the issuance of these permits, but later dissolved it and dismissed the complaint. The Court of Appeals reversed the District Court's decision, leading to the Supreme Court's review of the attorneys' fees awarded to the environmental groups.

This litigation was initiated by respondents Wilderness Society, Environmental Defense Fund, Inc., and Friends of the Earth in an attempt to prevent the issuance of permits by the Secretary of the Interior which were required for the construction of the trans-Alaska oil pipeline.

Issue

Whether the Court of Appeals erred in awarding attorneys' fees to the environmental groups based on the private attorney general doctrine.

Whether the Court of Appeals erred in awarding attorneys' fees to the environmental groups based on the private attorney general doctrine.

Rule

The American rule states that attorneys' fees are not ordinarily recoverable by the prevailing litigant in federal litigation unless authorized by statute.

Under the ‘America Rule’ that attorneys' fees are not ordinarily recoverable by the prevailing litigant in federal litigation in the absence of statutory authorization, respondents, which had instituted litigation to prevent issuance of Government permits required for construction of the trans-Alaska oil pipeline, cannot recover attorneys' fees from petitioner based on the ‘private attorney general’ approach erroneously approved by the Court of Appeals.

Analysis

The Supreme Court analyzed the historical context of the American rule and concluded that the judiciary does not have the authority to create exceptions to this rule without legislative guidance. The Court emphasized that the power to authorize the recovery of attorneys' fees lies solely with Congress.

At common law, costs were not allowed; but for centuries in England there has been statutory authorization to award costs, including attorneys' fees. Although the matter is in the discretion of the court, counsel fees are regularly allowed to the prevailing party.

Conclusion

The Supreme Court reversed the Court of Appeals' decision to award attorneys' fees to the environmental groups, reaffirming the American rule against such awards in the absence of statutory authorization.

The decision below must therefore be reversed.

Who won?

Alyeska Pipeline Service Co. prevailed in the Supreme Court because the Court ruled that the award of attorneys' fees was not permissible under the American rule.

Alyeska, the Court of Appeals held, could fairly be required to pay one-half of the full award to which respondents were entitled for having performed the functions of a private attorney general.

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