CRST Van Expedited, Inc. v. Equal Employment Opportunity Commission (578 U.S. 419)
U.S. Supreme Court · decided May 19, 2016 · Supreme Court Database (Spaeth)
- Citation
- 578 U.S. 419 · 136 S. Ct. 1642
- Decided
- May 19, 2016
- Term
- October Term 2015
- Vote
- 8–0
- Majority author
- Justice Kennedy
- Issue area
- Civil Rights
- Disposition
- Vacated and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Conservative
Opinion excerpt
Justice KENNEDY delivered the opinion of the Court. This case involves the interpretation of a statutory provision allowing district courts to award attorney's fees to defendants in employment discrimination actions. Under Title VII of the Civil Rights Act of 1964, 78 Stat. 253, as amended, 42 U.S.C. § 2000e et seq., which prohibits discrimination in employment, a district court may award attorney's fees to "the prevailing party." § 2000e-5(k). The Court of Appeals for the Eighth Circuit held that a Title VII defendant prevails only by obtaining a "ruling on the merits." 774 F.3d 1169, 1179 (2014) ; Marquart v. Lodge 837, Machinists and Aerospace Workers, 26 F.3d 842, 851-852 (1994). This Court disagrees with that conclusion. The Court now holds that a favorable ruling on the merits is not a necessary predicate to find that a defendant has prevailed. I Title VII of the Civil Rights Act of 1964 authorizes an award of attorney's fees in certain circumstances. The statute provides that "[i]n any action or proceeding under this subchapter the court, in its discretion, may allow the prevailing party, other than the [Equal Employment Opportunity] Commission or the United States, a reasonable attorney's fee (including expert fees) as part of the costs, and the Commission and the United States shall be liable for costs the same as a private person." § 2000e-5(k). Before deciding…
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