Plain-English summary
Court rules preliminary injunctions that end with mootness do not make a party a 'prevailing party' for §1988 fee awards
The Court held that plaintiffs who obtained only preliminary injunctive relief that later became moot are not "prevailing parties" eligible for attorney's fees under 42 U.S.C. §1988. The decision requires a judicial ruling that conclusively resolves the merits or creates an enduring change in the parties' legal relationship to qualify.
Why this matters
This decision narrows when civil-rights plaintiffs can recover attorney's fees. Many civil-rights and constitutional cases rely on fee-shifting statutes like §1988 so that private lawyers can pursue public-interest litigation. By requiring a conclusive, lasting judicial resolution rather than a temporary or predictive order, the ruling limits fee awards when litigation ends without a final merits decision — for example, because the case becomes moot or is voluntarily dismissed after interim relief.
Who may feel it
- Civil-rights and constitutional plaintiffs and their attorneys
- State and local governments defending civil-rights suits
- Public-interest legal organizations that rely on fee awards
- Lower courts deciding fee motions under 42 U.S.C. §1988