Buckhannon Board and Care Home v. West Virginia Department of Health and Human Resources

121 S. Ct. 1835 (2001) ; Clearinghouse Number: 53373

Description

U.S. Supreme Court Holds That "Catalyst Theory" Does Not Entitle Petitioner to Attorney Fees

Abstract

The Supreme Court held that the catalyst theory was not a permissible basis for the award of attorney fees under the Fair Housing Amendments Act of 1988 and the Americans with Disabilities Act . The catalyst theory posits that a plaintiff is the prevailing party if it achieves the desired result because the lawsuit brought about a voluntary change in defendant’s conduct. Petitioner assisted-living-residence operator failed a state fire marshal inspection because some residents were incapable of “self-preservation” as defined by state law. Ordered to close its facilities, petitioner sought a declaration from respondent state agency that the “self-preservation” requirement violated both Acts. Respondents agreed to stay the order to close pending the case’s resolution. The state legislature then eliminated the “self-preservation” requirement, and the district court dismissed the case as moot. Seeking attorney fees under both Acts, petitioner claimed that the catalyst theory entitled it to such fees. Noting that a “prevailing party” was one a court had awarded some relief, the Supreme Court found that both judgments on the merits and court-ordered consent decrees created a material alteration of the parties’ legal relationship and thus permitted an award. The “catalyst theory,” however, allowed an award when there was no judicially sanctioned change in the parties’ legal relationship. The Court held that defendant’s voluntary change in conduct, although perhaps accomplishing what plaintiff sought to achieve by the lawsuit, lacked the necessary judicial imprimatur on the change.

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Docket Date
2000-11-20 00:00:00+00:00