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the Supreme Court addressed whether drivers who obtained a preliminary injunction against a Virginia statute, later repealed, were entitled to attorney\'s fees under 42 U.S.C. § 1988(b). The Court determined that because the preliminary injunction did not provide enduring judicial relief that materially altered the legal relationship between the parties, the drivers were not \'prevailing parties\' eligible for such fees.
Holding
The single most important “bottom line” of what the Court decided in Lackey v. Stinnie.
The Court held that the drivers, who only obtained preliminary injunctive relief before the case became moot, do not qualify as \'prevailing parties\' eligible for attorney\'s fees under § 1988(b).
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 Procedural 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 by failing to provide sufficient notice or hearing before license suspension.
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 Remedies and Relief is relevant to Lackey v. Stinnie
The Court's decision focuses on whether the preliminary injunction constitutes enduring judicial relief that materially alters the legal relationship between the parties.
Syllabus excerpt (verbatim)Held: The plaintiff drivers here—who gained only preliminary injunctive relief before this action became moot—do not qualify as 'prevailing par[ties]' eligible for attorney's fees under § 1988(b) because no court conclusively resolved their claims by granting enduring judicial relief on the merits that materially altered the legal relationship between the parties.
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Why Equal Protection is relevant to Lackey v. Stinnie
The drivers argued that the statute violated equal protection as applied to people who cannot afford to pay fines due to their financial circumstances.
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.
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.
The judicial role here is limited.
