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Illustration for Lackey v. Stinnie
Docket 23-621

Lackey v. Stinnie

The Supreme Court considered whether plaintiffs who obtain a preliminary injunction but whose case becomes moot before a final judgment are eligible for attorney's fees as "prevailing parties" under federal civil rights law. The Court ruled that a preliminary injunction alone does not confer prevailing party status because it is a temporary measure rather than a conclusive resolution of the claims on the merits.

Status
Decided
Appeal from
United States Court of Appeals for the Fourth Circuit
Argued
Oct 8, 2024
Decision released
Feb 25, 2025

Decision briefing

The case in plain English

Start with the holding, why it matters, and the strongest takeaways from the opinions.

Why did the Court rule against the Virginia drivers?

The Supreme Court ruled 7-2 that a party who wins a preliminary injunction (a temporary court order) is not a 'prevailing party' entitled to attorney's fees if the case ends before a final judgment. The Court explained that these temporary wins do not conclusively resolve the legal claims on their merits. Because the case became moot (no longer a live legal issue) before a final decision, the plaintiffs did not meet the high bar for winning.

Will it become harder for people to sue the government?

This decision makes it harder for civil rights plaintiffs to recover legal costs when the government changes its behavior mid-lawsuit. For example, if a person sues over an unfair law and the state repeals it after a temporary court order, the person may still have to pay their own expensive legal bills. This could discourage lawyers from taking on important civil rights cases for people who cannot afford to pay.

How does this ruling change the 'American Rule' for legal costs?

Under the 'American Rule,' each side usually pays its own legal fees regardless of who wins. Congress created an exception for civil rights cases to encourage people to fight for their constitutional rights. This case clarifies that only a permanent, judicial victory counts as 'prevailing' under that federal law.

How did the justices divide on the definition of 'prevailing'?

Chief Justice John Roberts wrote the majority opinion for a 7-2 Court, joined by the other conservative justices and Justice Elena Kagan. Justice Ketanji Brown Jackson wrote a dissenting opinion, which was joined by Justice Sonia Sotomayor.

The term 'prevailing party' refers to a party who obtains enduring judicial relief that conclusively resolves their claim on the merits.

— Justice Chief Justice John Roberts(majority)

What is the final word on paying lawyers in civil rights cases?

A temporary court victory is not enough to force the losing side to pay the winner's attorney's fees if the case ends early.

What happens to future civil rights lawsuits now?

The case will return to the lower courts to be formally closed following the Supreme Court's instructions. Civil rights groups will likely look for new ways to ensure their legal costs are covered when the government settles or changes laws during a dispute.

What was the core dispute in Lackey v. Stinnie?

The case focused on whether Virginia drivers could collect attorney's fees after a court temporarily blocked a law that suspended licenses for unpaid court debts.

What are the real-world consequences for civil rights plaintiffs?

People suing the government may now face large legal bills even if they win a temporary victory that forces the government to change its ways.

What is the specific legal rule the Court established?

The Court held that 'prevailing party' status requires a permanent change in the legal relationship between parties that is caused by a final judicial order.

What is the next procedural step for this specific case?

The case is reversed and remanded (sent back) to the lower court to apply the Supreme Court's new ruling to the final fee request.

How does this fit into the broader trend of legal fee disputes?

This ruling reinforces a strict reading of fee-shifting statutes, making it more difficult for litigants to bypass the standard rule that everyone pays for themselves.

Where things stand

Timeline

Key court milestones at a glance.

Case Accepted
Arguments HeardOct 8, 2024
Decision ReleasedFeb 25, 2025

Source note

How this page is sourced

Official case materials anchor this page. Reporting is used only to add context and explain the dispute in plain English.

Page data last refreshed Mar 9, 2026.

Primary materials

Documents & resources

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Briefs

Opinions

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