RESPONDENT: Garland Independent School District
LOCATION: Dallas City Hall
DOCKET NO.: 87-1759
DECIDED BY: Rehnquist Court (1988-1990)
LOWER COURT: United States Court of Appeals for the Fifth Circuit
CITATION: 489 US 782 (1989)
ARGUED: Mar 01, 1989
DECIDED: Mar 28, 1989
Earl Luna - on behalf of the Respondents
Robert H. Chanin - on behalf of the Petitioners
Facts of the case
Media for Texas State Teachers Association v. Garland Independent School District
Audio Transcription for Oral Argument - March 01, 1989 in Texas State Teachers Association v. Garland Independent School District
William H. Rehnquist:
We'll hear argument first this morning in No. 87-1759, Texas State Teachers Association v. Garland Independent School District.
Robert H. Chanin:
Mr. Chief Justice, and may it please the Court.
The question presented by this case concerns the standard to be used in determining whether a plaintiff is a prevailing party for purposes of the Civil Rights Attorney's Fee Awards Act, Section 1988.
The parties urge two alternative standards.
The Respondents contend that the correct standard is the one used by the Fifth and Eleventh Circuits.
It is referred to as the central issue standard under which a plaintiff must prevail on the central issue by acquiring the primary relief sought.
On the basis of this standard, the court below held the Petitioners in this case were not prevailing parties and, therefore, ineligible for any fee award.
The standard urged by Petitioners was initially articulated by the First Circuit in Nadeau v. Heigemoe in 1978.
It is currently used by courts of appeal in 11 circuits, and it was characterized by this Court as a typical formulation in Hensley v. Eckerhart in 1983.
It is referred to as the significant issue standard which establishes plaintiffs as prevailing parties if they succeed on any significant issue in litigation which achieves some of the benefits the parties sought in bringing suit.
Let me note at the outset that the question as to the correct standard for prevailing party status does not in and of itself relate directly to the amount of fees that ultimately should be awarded to a plaintiff.
The standard at issue here is only the first stage of a two-stage process.
It is a threshold standard to establish an eligibility for fees.
If a plaintiff succeeds in crossing that threshold, the actual amount of fees to which he is entitled is determined by the district court after considering various factors, particularly the degree of success.
To put this another way, there is no dispute here about the fact that the results obtained is a crucial factor in the application of Section 1988.
The dispute concerns the stage of the process at which this factor should have its primary impact.
Should it be at the threshold eligibility stage to deny prevailing party status to a partially prevailing plaintiff and totally preclude any fee award, which is the Respondents' position?
Or should it have its primary impact at the second stage after prevailing party status has been achieved in determining the amount of reasonable fees in light of the results obtained?
This is the Petitioners' position.
In order to establish a framework for addressing this question, it is appropriate to begin with a brief review of the facts in this case, particularly since the briefs of the Respondents and their supporting amici present such a distorted picture of the merits outcome.
This case involves a regulation adopted by a public school district in Texas, the Garland Independent School District... I'll refer to it as GISD... which prohibited all communications regarding employee organizations on school grounds at any time during the school day, including teachers' lunch break, non-class periods and other free time.
The regulation covered face-to-face discussions and also prohibited any use of the school district's communications facilities, bulletin boards, teachers' mailboxes, PA systems.
Those were all precluded to disseminate any information regarding employee organizations.
This prohibition applied to communications by and among the teachers themselves, as well as the communications by outside representatives of employee organizations.
The Petitioners filed a 1983 action and succeeded in having the regulation struck down as it applied to teacher-to-teacher communications and as it applied to the GISD's communications facilities by the teachers themselves.
We were unsuccessful in regard to the prohibition against communications by outside representatives.
We considered this to be a significant victory, and judging by the vigorous efforts of the Respondents to overturn the ruling, so did they.
They left no stone unchallenged in seeking to reverse this ruling, including ultimately an appeal to this Court which summarily affirmed the Fifth Circuit on the merits in 1986.
In the course of its efforts to reverse, the Respondents did something else.