Lackey v. Stinnie
View Official PDFBelow are plain-language sections to help you understand what the Court decided in Lackey v. Stinnie and why it matters. Quotes are taken from the syllabus (the Court’s short summary at the start of the opinion).
Summary
A short, plain-English overview of Lackey v. Stinnie.
In Lackey v. Stinnie, the Supreme Court reviewed whether drivers who obtained a preliminary injunction against a Virginia statute, which suspended licenses for unpaid court fines, could be considered 'prevailing parties' eligible for attorney's fees under 42 U.S.C. § 1988(b). The statute was repealed before a final judgment, rendering the case moot. The District Court and a Fourth Circuit panel initially denied attorney's fees, but the Fourth Circuit en banc reversed. The Supreme Court ultimately reversed the Fourth Circuit's decision.
Holding
The single most important “bottom line” of what the Court decided in Lackey v. Stinnie.
The Court held that plaintiffs who only secured a preliminary injunction before their case became moot do not qualify as 'prevailing parties' eligible for attorney's fees under § 1988(b) because no enduring judicial relief was granted.
Constitutional Concepts
These are the Constitution-related themes that appear in Lackey v. Stinnie. Click a concept to see other cases that involve the same idea.
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Why Due Process is relevant to Lackey v. Stinnie
The case involves a challenge to a statute on the grounds that it violates procedural due process rights.
Syllabus excerpt (verbatim)The drivers alleged that the statute facially violated the Due Process Clause by 'failing to provide sufficient notice or hearing to any driver before license suspension.'
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Why Equal Protection is relevant to Lackey v. Stinnie
The case includes an argument that the statute discriminates against individuals based on their financial circumstances, implicating equal protection concerns.
Syllabus excerpt (verbatim)The drivers alleged that the statute...violated both the Due Process and Equal Protection Clauses 'as applied to people who cannot afford to pay due to their modest financial circumstances.'
Key Quotes
Short excerpts from the syllabus in Lackey v. Stinnie that support the summary and concepts above.
The plaintiff drivers here—who gained only preliminary injunctive relief before this action became moot—do not qualify as 'prevailing parties' eligible for attorney's fees under § 1988(b).
Preliminary injunctions do not make a party 'prevailing' because they do not conclusively decide the case on the merits.
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.