Lefemine v. Wideman

A plaintiff who is awarded an injunction without monetary damages is still entitled to attorney fees under 42 USC §1988 because an injunction is a form of actual relief that “materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.”

Petitioner appealed after the district court granted his motion for summary judgment and issued a permanent injunction against Respondent for violating Petitioner’s First Amendment rights but refused to award attorney’s fees because he was not a “prevailing party” as defined in 42 USC §1988.

The Court of Appeals for the Fourth Circuit affirmed, but the Supreme Court reversed, stating that Petitioner was a prevailing party because the district court’s judgment materially altered the legal relationship between the parties. The Court vacated the judgment and remanded with instructions to award Petitioner reasonable attorney’s fees provided that there were not “special circumstances [that] would render such an award unjust.”