RESPONDENT: Equal Employment Opportunity Commission
LOCATION: CRST International Headquarters
DOCKET NO.: 14-1375
DECIDED BY: Roberts Court (2016- )
LOWER COURT: United States Court of Appeals for the Eighth Circuit
CITATION: 578 US (2016)
GRANTED: Dec 04, 2015
ARGUED: Mar 28, 2016
DECIDED: May 19, 2016
Paul M. Smith - for the petitioner
Brian H. Fletcher - Assistant to the Solicitor General, for the respondent
Facts of the case
The Equal Employment Opportunity Commission (EEOC) filed a sexual harassment suit on behalf of approximately 270 female employees against CRST Van Expedited (CRST). Two years after filing the suit, the EEOC failed to identify the 270 women, and the district court ordered the EEOC to amend its list of 270 women to include only the women who wished to continue with the suit and to ensure that those women be available for deposition. The EEOC complied with the first court order and failed to fulfill the second before the deadline. CRST had filed seven motions to dismiss, and the district granted (or granted in part) six of the motions. CRST subsequently filed a bill of costs against the EEOC for $4,560,285.11, and the district court granted the fee award. The EEOC appealed, and the U.S. Court of Appeals for the Eighth Circuit reversed the fee award. The appellate court held that the EEOC’s pre-suit obligations were not elements of the claim and did not constitute a ruling on the merits that was eligible for fees.
Is a fee award available after the dismissal of a case for failure to satisfy pre-suit obligations?
Media for CRST Van Expedited v. EEOCAudio Transcription for Oral Argument - March 28, 2016 in CRST Van Expedited v. EEOC
Audio Transcription for Opinion Announcement - May 19, 2016 in CRST Van Expedited v. EEOC
John G. Roberts, Jr.:
Justice Kennedy has our opinion this morning in case 14-1375, CRST Van Expedited versus the EEOC.
Anthony M. Kennedy:
Title 7 of the Civil Rights Act of 1964 authorizes courts, in their discretion, to award attorneys fees to the prevailing party.
This Court has set out standards for fee awards to plaintiffs who prevail.
Now the Court, however, has not set forth in detail how courts, particularly district courts in the first instance, should determine whether a defendant has prevailed.
This case presents the question whether a defendant may prevail if the district court's ruling was not on the merits of the plaintiff's claim.
Petitioner CRST is a trucking company.
CRST requires its drivers to graduate from the company's training program before becoming a certified driver, and part of that training program in this case was a 28-day over the road trip with a veteran driver.
More than 10 years ago in the year 2005, a new driver named Monica Stark filed a charge with the Equal Employment Opportunity Commission.
She alleged that two male trainers sexually harassed her during her over the road training trip.
The Commission filed suit against the company, against CRST.
It alleged that CRST had subjected Stark and other similarly situated women to sexual harassment and a hostile work environment.
During discovery the commission identified over 250 allegedly aggrieved women far more than first forecast, the district court disposed of the commission's claims, in its claims in a series of orders.
It is most relevant here it dismissed the claims on behalf of 67 of the women for the commissions having failed adequately to investigate and conciliate those claims as the statute requires.
Over one judge's dissent the Court of Appeals for the Eighth Circuit affirmed that dismissal. Then on remand the district court awarded CRST over $4 million in attorney's fees.
The Court of Appeals reversed.
It followed its own precedent which established that a defendant prevails if that defendant has obtained a favorable judicial determination on the merits.
The Court of Appeals had held the dismissal of the claims on behalf of the 67 women was not a ruling on the merits.
The decision of the Court of Appeals is now vacated and the case is remanded.
Common sense undermines the premise that a defendant cannot prevail unless the relevant disposition is on the merits.
Plaintiffs and defendants come to court with different objectives.
A plaintiff seeks a material alteration in the legal relationship between the parties.
A defendant seeks to prevent this alteration to the extent it is in the plaintiff's favor.
A defendant might prefer a judgment vindicating its position regarding the substantive merits, but the defendant still has fulfilled its primary objective where the plaintiff's challenge is rebuffed irrespective of the precise reason for the ruling.
The defendant may prevail even with the court's final judgment rejects the plaintiff's claim for a non-merits reason.
The purpose of the statute authorizing attorneys’ fees, and attorney fee awards, is to allow prevailing defendants to recover whenever the plaintiff's claim was frivolous, unreasonable or groundless.
It would make little sense if Congress policy of sparing defendants from the costs of frivolous litigation depended on the distinction between merits-based and non-merits-based frivolousness.
The Commission urges alternative grounds for affirmance but the Court of Appeals has not addressed those issues.
It is not this Court's usual practice to adjudicate these sorts of questions in the first instance that precept is applicable here, especially in light of the extensive record in the case, and the fact that the commission has changed its litigating position.
The judgment of the Court of Appeals is vacated.
The case is remanded for further proceedings consistent with this opinion.