莱基诉斯廷尼案

Virginia drivers whose licenses were suspended under a state statute for failure to pay court fines sued the Commissioner of the Virginia DMV under 42 U.S.C. § 1983, alleging due process and equal protection violations. The District Court granted a preliminary injunction prohibiting enforcement of the statute. Before trial, the Virginia General Assembly repealed the law and required reinstatement of suspended licenses, rendering the case moot. The Fourth Circuit en banc held that plaintiffs qualified as "prevailing parties" entitled to attorney's fees under § 1988(b). The Supreme Court reversed in a 7-2 decision, holding that obtaining a preliminary injunction alone does not confer prevailing party status because no court conclusively resolved the claims on the merits with enduring judicial relief.

The Supreme Court reversed the Fourth Circuit's en banc decision and remanded the case. In a 7-2 opinion authored by Chief Justice Roberts, the Court held that the plaintiff drivers do not qualify as "prevailing parties" under § 1988(b) because preliminary injunctions do not conclusively resolve claims on the merits or grant enduring judicial relief that materially alters the legal relationship between parties. Justice Jackson authored a dissent joined by Justice Sotomayor.

Whether a plaintiff who obtains a preliminary injunction but whose case becomes moot before final judgment qualifies as a "prevailing party" eligible for attorney's fees under 42 U.S.C. § 1988(b). The Court addressed two questions: (1) whether a party must obtain a ruling that conclusively decides the merits rather than merely predicting likelihood of success, and (2) whether the change must be judicially sanctioned and enduring rather than resulting from a non-judicial event that moots the case.

The decision significantly restricts civil rights plaintiffs' ability to recover attorney's fees when they obtain preliminary relief but cases become moot before final judgment. It rejected unanimous circuit precedent and may discourage attorneys from taking civil rights cases where preliminary injunctive relief is the likely outcome. The ruling affects access to justice for low-income plaintiffs challenging government policies, as fee-shifting provisions are critical for funding civil rights litigation. The decision also impacts employment discrimination and other civil rights litigation under related statutes.