US SUPREME COURT DECISIONS
James v. Boise, 577 U.S. ___ (2016)
Under federal law, a court has discretion to “allow the prevailing party, other than the United States, a reasonable attorney’s fee” in a civil rights lawsuit filed under 42 U.S.C. 1983 or 42 U.S.C. 1988. The Supreme Court has interpreted section 1988 to permit a prevailing defendant to recover fees only if “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The Idaho Supreme Court concluded that it was not bound by that interpretation and awarded attorney’s fees under section 1988 to a prevailing defendant without first determining that “the plaintiff ’s action was frivolous, unreasonable, or without foundation.” The fee award rested solely on that court's interpretation of federal law; the court explicitly refused to award fees under state law. The Supreme Court reversed. Section 1988 is a federal statute; once the Supreme Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law. If state courts were permitted to disregard the Court’s rulings on federal law, “the laws, the treaties, and the constitution of the United States would be different in different states, and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two states."
Annotation
Primary Holding
State supreme courts are bound by the U.S. Supreme Court's interpretation of federal statutes, including those that permit a prevailing defendant to recover attorney's fees.Read more
Opinions
SUPREME COURT OF THE UNITED STATES
MELENE JAMES v. CITY OF BOISE, IDAHO, et al.
on petition for writ of certiorari to the supreme court of idaho
No. 15–493. Decided January 25, 2016
Per Curiam.
Under federal law, a court has discretion to “allow the prevailing party, other than the United States, a reason-able attorney’s fee” in a civil rights lawsuit filed under 42 U. S. C. §1983. 42 U. S. C. §1988. In Hughes v. Rowe, 449 U. S. 5 (1980) (per curiam), this Court interpreted §1988 to permit a prevailing defendant in such a suit to recover fees only if “the plaintiff’s action was frivolous, unreasonable, or without foundation.” Id., at 14 (quoting Christiansburg Garment Co. v. EEOC, 434 U. S. 412, 421 (1978) (internal quotation marks omitted)).
In the decision below, the Idaho Supreme Court concluded that it was not bound by this Court’s interpretation of §1988 in Hughes. According to that court, “[a]lthough the Supreme Court may have the authority to limit the discretion of lower federal courts, it does not have the authority to limit the discretion of state courts where such limitation is not contained in the statute.” 158 Idaho713, 734, 351 P. 3d 1171, 1192 (2015). The court then pro-ceeded to award attorney’s fees under §1988 to a prevailing defendant without first determining that “the plaintiff’s action was frivolous, unreasonable, or without foundation.” The court’s fee award rested solely on its interpretation of federal law; the court explicitly refused to award fees under state law. Id., at 734–735, 351 P. 3d, at 1192–1193. We grant certiorari, and now reverse.
Section 1988 is a federal statute. “It is this Court’s responsibility to say what a [federal] statute means, and once the Court has spoken, it is the duty of other courts to respect that understanding of the governing rule of law.” Nitro-Lift Technologies, L. L. C. v. Howard, 568 U. S. ___, ___ (2012) (per curiam) (slip op., at 5) (quoting Rivers v. Roadway Express, Inc., 511 U. S. 298, 312 (1994) (internal quotation marks omitted)). And for good reason. As Justice Story explained 200 years ago, if state courts were permitted to disregard this Court’s rulings on federal law, “the laws, the treaties, and the constitution of the United States would be different in different states, and might, perhaps, never have precisely the same construction, obligation, or efficacy, in any two states. The public mischiefs that would attend such a state of things would be truly deplorable.” Martin v. Hunter’s Lessee, 1 Wheat. 304, 348 (1816).
The Idaho Supreme Court, like any other state or fed-eral court, is bound by this Court’s interpretation of federal law. The state court erred in concluding otherwise. The judgment of the Idaho Supreme Court is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.
It is so ordered.
Disclaimer: Official Supreme Court case law is only found in the print version of the United States Reports. Law library cases is provided for general informational purposes only, and may not reflect current legal developments, verdicts or settlements. We make no warranties or guarantees about the accuracy, completeness, or adequacy of the information contained on this site or information linked to from this site. Please check official sources.
Law library case is a forum for attorneys to summarize, comment on, and analyze case law published on our site. Law library makes no guarantees or warranties that the annotations are accurate or reflect the current state of law, and no annotation is intended to be, nor should it be construed as, legal advice. Contacting Law library or any attorney through this site, via web form, email, or otherwise, does not create an attorney-client relationship.
First Party
Melene JamesSecond Party
City of Boise, IdahoOfficial Citation
577 U.S. __ (2016)Docket No.
15-493Granted
January 24, 2016Decided
January 24, 2016
