Texas State Teachers Association v. Garland Independent School District

Citation103 L.Ed.2d 866,489 U.S. 782,109 S.Ct. 1486
Decision Date28 March 1989
Docket NumberNo. 87-1759,87-1759
PartiesTEXAS STATE TEACHERS ASSOCIATION, et al., Petitioners v. GARLAND INDEPENDENT SCHOOL DISTRICT et al
CourtUnited States Supreme Court
Syllabus

Petitioners, state and local teachers' associations and several of their members and employees, brought suit in the District Court under 42 U.S.C. § 1983, alleging that respondent school district's policy of prohibiting communications by or with teachers during the schoolday concerning employee organizations violated their First and Fourteenth Amendment rights in various particular respects. The District Court granted the school district summary judgment on most of petitioners' claims. The Court of Appeals affirmed in part and reversed in part, granting petitioners summary judgment on their claims that the school district's actions in prohibiting teacher-to-teacher discussion of employee organizations during the schoolday and teacher use of internal mail and billboard facilities to discuss such organizations were unconstitutional. After this Court summarily affirmed the Court of Appeals' judgment, petitioners filed the instant application for an award of attorney's fees under 42 U.S.C. § 1988. The District Court held that petitioners were not "prevailing parties" within the meaning of § 1988 and thus were ineligible for any fee award, since, under Fifth Circuit precedent, the test for prevailing party status was whether the plaintiff prevailed on the central issue in the litigation by acquiring the primary relief sought. The Court of Appeals affirmed, ruling that, although petitioners had achieved success on "significant secondary issues," they had not prevailed on the central issue in the lawsuit—the constitutionality of the school district's policy of limiting employee organizations' access to teachers and school facilities during school hours.

Held:

1. The lower courts' "central issue" test for determining "prevailing party" status under § 1988 is rejected in favor of a standard requiring only that parties " 'succeed on any significant issue in the litigation which achieves some of the benefit [they] sought in bringing the suit.' " Nadeau v. Helgemoe, 581 F.2d 275, 278-279, quoted in Hensley v. Eckerhart, 461 U.S. 424, 433, 103 S.Ct. 1933, 1939, 76 L.Ed.2d 40. Pp. 788-793.

(a) The "central issue" test is directly contrary to the thrust of Hensley, supra, which, although it did not adopt one particular standard for determining prevailing party status, nevertheless indicated that the degree of the plaintiff's success in relation to the lawsuit's overall goals is a factor critical to the determination of the size of a reasonable fee, not to eligibility for a fee award at all. The "central issue" test is also incongruous in light of the clear congressional intent, as expressed in § 1988's legislative history, that interim fee awards be available o partially prevailing civil rights plaintiffs. Congress cannot have meant "prevailing party" status to depend entirely on the timing of a fee request: A prevailing party must be one who has succeeded on any significant claim affording it some of the relief sought, either pendente lite or at the conclusion of the litigation. Furthermore, the search for the "central" and "tangential" issues in the lawsuit, or for the "primary" as opposed to the "secondary" relief sought, forces district courts to focus on the subjective intent of the parties, which is almost impossible to determine; is irrelevant to § 1988's prime purposes and essentially unhelpful in defining the term "prevailing party"; and is sure to provoke prolonged litigation of fee disputes. Pp. 788-791.

(b) A plaintiff has crossed the threshold to a fee award of some kind if he or she satisfies the Nadeau "significant issue" "some benefit" standard. Under that standard, at a minimum, the plaintiff must be able to point to a resolution of the dispute which materially alters the parties' legal relationship in a manner which Congress sought to promote in the fee statute. Hewitt v. Helms, 482 U.S. 755, 760, 107 S.Ct. 2672, 2675-2676, 96 L.Ed.2d 654. Where the plaintiff's success on a legal claim can be characterized as purely technical or de minimis, a district court would be justified in concluding that it is so insignificant as to be insufficient to support prevailing party status. However, where the parties' relationship has been materially changed, the degree of the plaintiff's overall success goes to the reasonableness of the award under Hensley, supra, not to the availability of the fee award vel non. Pp. 791-793.

2. Petitioners are "prevailing parties" within the meaning of § 1988. They have prevailed on a significant issue in the litigation, in that their success has materially altered the school district's policy limiting the rights of teachers to communicate with each other concerning employee organizations and union activities. Moreover, they have obtained some of the relief they sought, a judgment vindicating the rights of public employees in the workplace. They have thus served the "private attorney general" role which Congress meant to promote in enacting § 1988. P. 793.

837 F.2d 190, (CA5 1988) reversed and remanded.

O'CONNOR, J., delivered the opinion for a unanimous Court.

Robert H. Chanin, Washington, D.C., for petitioners.

Earl Luna, Dallas, Tex., for respondents.

Justice O'CONNOR delivered the opinion of the Court.

We must decide today the proper standard for determining whether a party has "prevailed" in an action brought under certain civil rights statutes such that the party is eligible for an award of attorney's fees under the Civil Rights Attorney's Fees Awards Act of 1976, 90 Stat. 2641, 42 U.S.C. § 1988. This is an issue which has divided the Courts of Appeals both before and after our decision in Hensley v. Eckerhart, 461 U.S. 424, 103 S.Ct. 1933, 76 L.Ed.2d 40 (1983). The Courts of Appeals for the Fifth and Eleventh Circuits require that a party succeed on the "central issue" in the litigation and achieve the "primary relief sought" to be eligible for an award of attorney's fees under § 1988. See, e.g., Simien v. San Antonio, 809 F.2d 255, 258 (CA5 1987); Martin v. Heckler, 773 F.2d 1145, 1149 (CA11 1985) (en banc). Most of the other Federal Courts of Appeals have applied a less demanding standard, requiring only that a party succeed on a significant issue and receive some of the relief sought in the lawsuit to qualify for a fee award. See, e.g., Gingras v. Lloyd, 740 F.2d 210, 212 (CA2 1984); Lampher v. Zagel, 755 F.2d 99, 102 (CA7 1985); Fast v. School Dist. of Ladue, 728 F.2d 1030, 1032-1033 (CA8 1984) (en banc); Lummi Indian Tribe v. Oltman, 720 F.2d 1124, 1125 (CA9 1983); Nephew v. Aurora, 766 F.2d 1464, 1466 (CA10 1985). In this case, the Court of Appea § for the Fifth Circuit applied the "central issue" test and concluded that petitioners here were not prevailing parties under § 1988. Because of the conflicting views in the Courts of Appeals, and because of the importance of the definition of the term "prevailing party" to the application of § 1988 and other federal fee shifting statutes, we granted certiorari. 488 U.S. 815, 109 S.Ct. 51, 102 L.Ed.2d 30 (1988).

I

On March 31, 1981, petitioners, the Texas State Teachers Association, its local affiliate the Garland Education Association, and several individual members and employees of both organizations brought suit under 42 U.S.C. § 1983 against respondent Garland Independent School District and various school district officials. Petitioners' complaint alleged that the school district's policy of prohibiting communications by or with teachers during the schoolday concerning employee organizations violated petitioners' First and Fourteenth Amendment rights. In particular, petitioners focused their attack on the school district's Administrative Regulation 412, which prohibits employee organizations access to school facilities during school hours and proscribes the use of school mail and internal communications systems by employee organizations. The school district's regulations do permit employee organizations to meet with, or recruit, teachers on school premises before or after the schoolday "upon request and approval by the local school principal." Brief for Respondents 4-5.

On cross motions for summary judgment, the District Court rejected petitioners' claims in almost all respects. The court found that under Perry Education Assn. v. Perry Local Educators' Assn., 460 U.S. 37, 103 S.Ct. 948, 74 L.Ed.2d 794 (1983), the prohibitions on union access to teachers themselves and to internal communication media during school hours were constitutional. App. to Pet. for Cert. 55a-57a. The District Court also rejected petitioners' claim that the school district's policies were unconstitutional in that they prohibited teachers' discussion or promotion of employee organizations among themselves during school hours. Id., at 46a, n. 13. As to teacher discussion of employee organizations, the court found that even if some school officials interpreted the regulations to prohibit such speech, there had been no attempt to enforce such an interpretation. As to teacher-to-teacher speech promoting employee organizations, the court found that the record indicated that the school district did prohibit such speech, but concluded that this prohibition was constitutional. Ibid. The District Court did find for petitioners on one issue: it held that the requirement of school principal approval of teacher meetings with union representatives after school hours was unconstitutionally vague in that no guidelines limited the discretion of the principal's decision to grant or deny access to the campus. Id., at 58a. The District Court found that this issue was of "minor significance," since there was no evidence in the record to indicate that school officials had ever denied employee organizations the use of school premises during...

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