Melene James v. City of Boise, Idaho, et al. (577 U.S. 306)
U.S. Supreme Court · decided January 25, 2016 · Supreme Court Database (Spaeth)
- Citation
- 577 U.S. 306 · 136 S. Ct. 685
- Decided
- January 25, 2016
- Term
- October Term 2015
- Vote
- 9–0
- Issue area
- Attorneys
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
PER CURIAM. Under federal law, a court has discretion to "allow the prevailing party, other than the United States, a reasonable attorney's fee" in a civil rights lawsuit filed under 42 U.S.C. § 1983. 42 U.S.C. § 1988. In Hughes v. Rowe, 449 U.S. 5, 101 S.Ct. 173, 66 L.Ed.2d 163 (1980) (per curiam ), this Court interpreted § 1988 to permit a prevailing defendant in such a suit to recover fees only if "the plaintiff's action was frivolous, unreasonable, or without foundation." Id., at 14, 101 S.Ct. 173 (quoting Christiansburg Garment Co. v. EEOC, 434 U.S. 412, 421, 98 S.Ct. 694, 54 L.Ed.2d 648 (1978) (internal quotation marks omitted)). In the decision below, the Idaho Supreme Court concluded that it was not bound by this Court's interpretation of § 1988 in Hughes . According to that court, "[a]lthough the Supreme Court may have the authority to limit the discretion of lower federal courts, it does not have the authority to limit the discretion of state courts where such limitation is not contained in the statute." 158 Idaho 713, 734, 351 P.3d 1171, 1192 (2015). The court then proceeded to award attorney's fees under § 1988 to a prevailing defendant without first determining that "the plaintiff's action was frivolous, unreasonable, or without foundation." The court's fee award rested solely on its interpretation of federal law; the court explicitly refused to award fees under…
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