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lawsuitplaintiffattorneystatuteappeal
plaintiffdefendantdamagesattorneystatuteappealmotion

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Morillo-Cedron v. Dist. Dir.

Facts

The Administrative Appeals Office ordered the District Director to act regarding the plaintiffs who were applicants for lawful permanent residency. When time passed without any action by the District Director, plaintiffs filed suit in federal district court for mandamus relief. The district court found that the plaintiffs' lawsuit was the catalyst which caused the Director to process their applications, leading to the award of costs and attorney's fees under the EAJA.

The Administrative Appeals Office ('AAO') ordered the District Director to act pursuant to AAO rulings regarding the plaintiffs who were applicants for lawful permanent residency. When time passed without any action by the District Director, plaintiffs filed suit in federal district court for mandamus relief. The plaintiffs also sought costs under 28 U.S.C. 2412(a) , and attorney's fees and expenses under the EAJA, 28 U.S.C. 2412(d) .

Issue

Whether the district court erred in concluding that Buckhannon did not apply to the EAJA, and therefore, erred in finding that the plaintiffs were entitled to an award of costs and attorney's fees under the 'catalyst theory.'

Whether the district court erred in concluding that Buckhannon did not apply to the EAJA, and therefore, erred in finding that the plaintiffs were entitled to an award of costs and attorney's fees under the 'catalyst theory.'

Rule

The term 'prevailing party' is a legal term of art, defined as a party in whose favor a judgment is rendered, and requires a court-ordered change in the legal relationship between the parties. The Supreme Court in Buckhannon rejected the 'catalyst theory' for determining prevailing party status under fee-shifting statutes.

The term 'prevailing party' is a legal term of art. 532 U.S. at 603, 121 S. Ct. at 1839 . Black's Law Dictionary 1145 (7th ed. 1999) defines 'prevailing party' as '[a] party in whose favor a judgment is rendered, regardless of the amount of damages awarded.' The Court explained that a 'prevailing party' is one who has been awarded some relief by the court; i.e., some court-ordered change in the legal relationship between the plaintiff and the defendant. 532 U.S. at 604, 121 S. Ct. at 1840 ; see also Smalbein , 353 F.3d at 904 . In so deciding, the Court rejected the 'catalyst theory' because it permits an award where there is no judicially sanctioned change in the legal relationship of the parties.

Analysis

The court applied the rule by determining that the plaintiffs did not achieve a court-ordered change in their legal relationship with the Director, as the Director voluntarily processed their applications before any final judgment was entered. The court emphasized that the plaintiffs did not litigate to judgment the Director's failure to process their applications, thus they were not considered prevailing parties under the EAJA.

In reviewing the record, we observe that the district court did not apply Buckhannon to the present case because it decided that since the Supreme Court in Buckhannon only addressed the Fair Housing Act ('FHA') and the Americans with Disabilities Act ('ADA'), its holding and reasoning did not apply to the EAJA. Even though we agree with the district court that Buckhannon involved different statutes, the Supreme Court clearly rejected the use of the 'catalyst theory,' which the district court employed in this case.

Conclusion

The court reversed the district court's award of fees and costs and remanded the cause for further proceedings.

Accordingly, because we hold that the district court erred in granting the plaintiffs' motion for attorney's fees and costs under the EAJA, we reverse its order and remand this case for further proceedings consistent with this opinion.

Who won?

The District Director prevailed in the case because the court found that the plaintiffs were not prevailing parties under the EAJA, as they did not obtain a court-ordered change in their legal relationship with the Director.

The Government contends that is does; the plaintiffs contend that it does not, and, even if it does, the district court appropriately granted costs and attorney's fees in this case because it determined that the Government acted unreasonably and unjustifiably when it did not process the plaintiffs' applications as required.

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