Lackey v. Stinnie, 2025 U.S. LEXIS 866 (U.S. Supreme Court, February 25, 2025) (Roberts, J.)
Drivers whose licenses were suspended under a Virginia statute for failure to pay court fines sued the Commissioner of the Virginia Department of Motor Vehicles under 42 U. S. C. §1983, challenging the statute as unconstitutional. The District Court granted a preliminary injunction prohibiting the Commissioner from enforcing the statute. Before trial, the Virginia General Assembly repealed the statute and required reinstatement of licenses suspended under the law. The parties then agreed to dismiss the pending case as moot.
We have held that, for the purposes of §1988(b), a plaintiff “prevails” when a court grants enduring judicial relief that constitutes a “material alteration of the legal relationship of the parties.” Texas State Teachers Ass’n v. Garland Independent School Dist., 489 U.S. 782, 792-793, 109 S. Ct. 1486, 103 L. Ed. 2d 866 (1989). For example, we have ruled that a plaintiff may qualify as a “prevailing party” based on an award of nominal damages, Farrar v. Hobby, 506 U. S. 103, 112, 113 S. Ct. 566, 121 L. Ed. 2d 494 (1992), or a final victory on a material even if not predominant claim, Texas State Teachers Ass’n, 489 U. S., at 791-793, 109 S. Ct. 1486, 103 L. Ed. 2d 866. By contrast, a party does not qualify as a “prevailing party” when a court of appeals overturns directed verdicts and discovery orders entered against him, Hanrahan v. Hampton, 446 U. S. 754, 756, 100 S. Ct. 1987, 64 L. Ed. 2d 670 (1980) (per curium), or when a court enters a declaratory judgment but does not modify the defendant’s behavior toward the plaintiff, Rhodes v. Stewart, 488 U. S. 1, 3-4, 109 S. Ct. 202, 102 L. Ed. 2d 1 (1988) (per curiam) (holding that no fees were available under §1988 when the judgment afforded no relief to the plaintiff due to mootness).
A plaintiff who wins a transient victory on a preliminary injunction does not become a “prevailing party” simply because external events convert the transient victory into a lasting one. Rather, a plaintiff “prevails” under the statute when a court conclusively resolves a claim by granting enduring judicial relief on the merits that materially alters the legal relationship between the parties.
The availability of fees following the entry of a court ordered consent decree is fully consistent with the rule we announce today. A consent decree reflects the parties’ own resolution of the merits, but it is approved and given force of law by the court. Violation of a consent decree is enforceable by a citation for contempt. Ibid. So a consent decree is like a final judgment in the relevant ways: It conclusively resolves the claim, bears a judicial imprimatur, and may grant enduring relief that materially alters the legal relationship between the parties. That is why “[w]e have only awarded attorney’s fees where the plaintiff has received a judgment on the merits or obtained a court-ordered consent decree.”
