Texas St. Teach. Ass'n v. Garland ISD
Annotate this Case
489 U.S. 782 (1989)
U.S. Supreme Court
Texas St. Teach. Ass'n v. Garland ISD, 489 U.S. 782 (1989)
Texas State Teachers Association v. Garland
Independent School District
Argued March 1, 1989
Decided March 28, 1989
489 U.S. 782
Petitioners, state and local teachers' associations and several of their members and employees, brought suit in the District Court under 42 U.S.C. § 1983, alleging that respondent school district's policy of prohibiting communications by or with teachers during the schoolday concerning employee organizations violated their First and Fourteenth Amendment rights in various particular respects. The District Court granted the school district summary judgment on most of petitioners' claims. The Court of Appeals affirmed in part and reversed in part, granting petitioners summary judgment on their claims that the school district's actions in prohibiting teacher-to-teacher discussion of employee organizations during the schoolday and teacher use of internal mail and billboard facilities to discuss such organizations were unconstitutional. After this Court summarily affirmed the Court of Appeals' judgment, petitioners filed the instant application for an award of attorney's fees under 42 U.S.C. § 1988. The District Court held that petitioners were not "prevailing parties" within the meaning of § 1988, and thus were ineligible for any fee award, since, under Fifth Circuit precedent, the test for prevailing party status was whether the plaintiff prevailed on the central issue in the litigation by acquiring the primary relief sought. The Court of Appeals affirmed, ruling that, although petitioners had achieved success on "significant secondary issues," they had not prevailed on the central issue in the lawsuit -- the constitutionality of the school district's policy of limiting employee organizations' access to teachers and school facilities during school hours.
1. The lower courts' "central issue" test for determining "prevailing party" status under § 1988 is rejected in favor of a standard requiring only that parties "succeed on any significant issue in the litigation which achieves some of the benefit [they] sought in bringing the suit.'" Nadeau v. Helgemoe, 581 F.2d 275, 278-279, quoted in Hensley v. Eckerhart, 461 U. S. 424, 461 U. S. 433. Pp. 489 U. S. 788-793.
(a) The "central issue" test is directly contrary to the thrust of Hensley, supra, which, although it did not adopt one particular standard
for determining prevailing party status, nevertheless indicated that the degree of the plaintiff's success in relation to the lawsuit's overall goals is a factor critical to the determination of the size of a reasonable fee, not to eligibility for a fee award at all. The "central issue" test is also incongruous in light of the clear congressional intent, as expressed in § 1988's legislative history, that interim fee awards be available to partially prevailing civil rights plaintiffs. Congress cannot have meant "prevailing party" status to depend entirely on the timing of a fee request: a prevailing party must be one who has succeeded on any significant claim affording it some of the relief sought, either pendente lite or at the conclusion of the litigation. Furthermore, the search for the "central" and "tangential" issues in the lawsuit, or for the "primary" as opposed to the "secondary" relief sought, forces district courts to focus on the subjective intent of the parties, which is almost impossible to determine; is irrelevant to § 1988's prime purposes and essentially unhelpful in defining the term "prevailing party"; and is sure to provoke prolonged litigation of fee disputes. Pp. 489 U. S. 788-791.
(b) A plaintiff has crossed the threshold to a fee award of some kind if he or she satisfies the Nadeau "significant issue" -- "some benefit" standard. Under that standard, at a minimum, the plaintiff must be able to point to a resolution of the dispute which materially alters the parties' legal relationship in a manner which Congress sought to promote in the fee statute. Hewitt v. Helms, 482 U. S. 755, 482 U. S. 760. Where the plaintiff's success on a legal claim can be characterized as purely technical or de minimis, a district court would be justified in concluding that it is so insignificant as to be insufficient to support prevailing party status. However, where the parties' relationship has been materially changed, the degree of the plaintiff's overall success goes to the reasonableness of the award under Hensley, supra, not to the availability of the fee award vel non. Pp. 489 U. S. 791-793.
2. Petitioners are "prevailing parties" within the meaning of § 1988. They have prevailed on a significant issue in the litigation, in that their success has materially altered the school district's policy limiting the rights of teachers to communicate with each other concerning employee organizations and union activities. Moreover, they have obtained some of the relief they sought, a judgment vindicating the rights of public employees in the workplace. They have thus served the "private attorney general" role which Congress meant to promote in enacting § 1988. P. 489 U. S. 793.
837 F.2d 190, reversed and remanded.
O'CONNOR, J., delivered the opinion for a unanimous Court.