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Keywords

defendantattorneystatuteprecedent

lawsuitplaintiffdefendantattorneyappealmotionrespondent

Related Cases

Buckhannon Bd. and Care Home, Inc. v. West Virginia Dept. of Health and Human Resources, 532 U.S. 598, 121 S.Ct. 1835, 149 L.Ed.2d 855, 11 A.D. Cases 1300, 21 NDLR P 1, 01 Cal. Daily Op. Serv. 4279, 2001 Daily Journal D.A.R. 5238, 14 Fla. L. Weekly Fed. S 287, 2001 DJCAR 2590

Facts

Buckhannon Board and Care Home, Inc. failed an inspection by the West Virginia fire marshal's office because some residents were deemed incapable of 'self-preservation' as defined by state law. Following cease and desist orders requiring the closure of its facilities, Buckhannon and others brought suit against the state, claiming the 'self-preservation' requirement violated the Fair Housing Amendments Act and the Americans with Disabilities Act. The state legislature later eliminated this requirement, leading to the dismissal of the case as moot.

Buckhannon Board and Care Home, Inc. failed an inspection by the West Virginia Office of the State Fire Marshal because some of the residents were incapable of 'self-preservation' as defined under state law. On October 28, 1997, after receiving cease and desist orders requiring the closure of its residential care facilities within 30 days, Buckhannon Board and Care Home, Inc., on behalf of itself and other similarly situated homes and residents (hereinafter petitioners), brought suit in the United States District Court for the Northern District of West Virginia against the State of West Virginia, two of its agencies, and 18 individuals (hereinafter respondents), seeking declaratory and injunctive relief that the 'self-preservation' requirement violated the Fair Housing Amendments Act of 1988 (FHAA) and the Americans with Disabilities Act of 1990 (ADA).

Issue

Whether a party can be considered a 'prevailing party' under the Fair Housing Amendments Act and the Americans with Disabilities Act if they have not secured a judgment on the merits or a court-ordered consent decree, but have achieved the desired result due to a voluntary change in the defendant's conduct.

The question presented here is whether this term includes a party that has failed to secure a judgment on the merits or a court-ordered consent decree, but has nonetheless achieved the desired result because the lawsuit brought about a voluntary change in the defendant's conduct.

Rule

The term 'prevailing party' in the context of fee-shifting statutes requires a party to have received some relief from a court, either through a judgment on the merits or a court-ordered consent decree.

A 'prevailing party' is one who has been awarded some relief by a court. See, e.g., Hanrahan v. Hampton, 446 U.S. 754, 758, 100 S.Ct. 1987, 64 L.Ed.2d 670.

Analysis

The Supreme Court analyzed the definitions and precedents surrounding the term 'prevailing party' and concluded that the 'catalyst theory'—which allows a party to claim prevailing status based on a voluntary change in the defendant's conduct—does not meet the statutory requirements. The Court emphasized that a judicially sanctioned change in the legal relationship between the parties is necessary for an award of attorney's fees.

The 'catalyst theory,' however, allows an award where there is no judicially sanctioned change in the parties' legal relationship. A defendant's voluntary change in conduct, although perhaps accomplishing what the plaintiff sought to achieve by the lawsuit, lacks the necessary judicial imprimatur on the change.

Conclusion

The Supreme Court affirmed the lower court's decision, ruling that the 'catalyst theory' is not a permissible basis for awarding attorney's fees under the Fair Housing Amendments Act and the Americans with Disabilities Act.

For the reasons stated above, we hold that the 'catalyst theory' is not a permissible basis for the award of attorney's fees under the FHAA, 42 U.S.C. § 3613(c)(2), and ADA, 42 U.S.C. § 12205.

Who won?

The state of West Virginia prevailed in the case because the Supreme Court ruled that Buckhannon Board and Care Home, Inc. did not qualify as a 'prevailing party' under the relevant statutes.

The District Court accordingly denied the motion and, for the same reason, the Court of Appeals affirmed in an unpublished, per curiam opinion.

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