Lackey v. Stinnie

Minute Summary

This case was about whether drivers in Virginia, whose licenses were suspended for not paying court fines, could be considered "prevailing parties" under federal law and qualify for attorney's fees after the law they were challenging was repealed. The drivers sued under 42 U.S.C. 1983, claiming that Virginia's automatic license suspension law violated their constitutional rights. The District Court issued a preliminary injunction, which temporarily stopped the state from enforcing the law against them. Before the case reached trial, Virginia repealed the law and reinstated the suspended licenses, making the case moot, meaning there was no longer an issue for the court to decide.

The drivers then asked for their attorney's fees under 42 U.S.C. 1988(b), which allows courts to award fees to the "prevailing party" in civil rights cases. The Supreme Court ruled that because the drivers had only won a temporary victory, the preliminary injunction, and did not obtain a final ruling on the merits of their case, they were not entitled to attorney's fees. The ruling emphasized that to be considered a "prevailing party," a plaintiff must win a permanent legal change through a final judgment or a court-approved settlement, not just an interim victory.

Important Definitions

42 U.S.C. 1983: A federal law that allows people to sue state officials for violating their constitutional rights.

42 U.S.C. 1988(b): A law that allows courts to award attorney's fees to the winning side in civil rights cases.

Preliminary Injunction: A temporary court order that prevents a law or policy from being enforced while a case is ongoing.

Mootness: When a case is no longer relevant because the issue has been resolved outside of court.

Prevailing Party: A person who wins a case and gains a permanent legal benefit as a result.

Judicial Imprimatur: A court's official approval of a legal ruling that permanently changes the rights of the parties involved.

Extended Summary

In Lackey v. Stinnie, Virginia drivers sued the state's Department of Motor Vehicles, arguing that a law suspending driver's licenses for unpaid court fines violated their constitutional rights. They claimed the law unfairly punished people who were unable to pay and denied them due process under the Fourteenth Amendment.

The District Court issued a preliminary injunction, temporarily blocking the enforcement of the law while the case continued. Before the case could reach a final decision, the Virginia General Assembly repealed the law, reinstating the suspended licenses and effectively making the case moot.

The drivers then requested attorney's fees under 1988(b), arguing that their lawsuit had led to the law's repeal and that the preliminary injunction provided them with meaningful relief. The District Court and the Fourth Circuit Court of Appeals ruled in favor of the drivers, stating that even though the case became moot, the preliminary injunction was enough to make them the "prevailing party" under the law.

The U.S. Supreme Court disagreed. It ruled that a preliminary injunction alone does not make a plaintiff a "prevailing party" because it is only a temporary decision. To qualify for attorney's fees under 1988(b), a plaintiff must win a permanent legal victory that changes the legal relationship between the parties—such as a final court ruling or a legally binding settlement.

The Court emphasized that a preliminary injunction does not prove a plaintiff has won on the merits because it is based on a lower standard—likelihood of success rather than actual success. Since the law was repealed before a final ruling, the case never reached a true legal conclusion, and therefore, the plaintiffs were not entitled to fees.

It is so ordered.

Think of It Like This

Imagine a student is being unfairly punished by their school and asks a judge to pause the punishment while they fight their case. The judge agrees and temporarily stops the punishment, but before the case is officially decided, the school changes the rule and drops the punishment. The student never gets a final court ruling proving they were right, so they don't qualify for a legal victory—even though the situation changed in their favor.

Similarly, the drivers in Lackey v. Stinnie got temporary relief from the preliminary injunction, but because the case was never fully decided, they were not considered winners under the law and could not recover their attorney's fees.