CRST Van Expedited, Inc. v. EEOC

A judgment on the merits is not necessary to find that a defendant has prevailed for the purposes of determining whether a defendant can recover attorney’s fees.

Title VII of the Civil Rights Act of 1964 provides that a court may allow the prevailing party to recover an attorney’s fee. Following an allegation of sexual harassment by a CRST employee, the Equal Employment Opportunity Commission ("EEOC") filed suit against CRST, alleging that CRST subjected numerous employees to a sexually hostile work environment. The district court dismissed the EEOC’s claims for a variety of procedural reasons and found CRST to be the prevailing party. The Court then granted CRST’s motion for attorney’s fees. The Eighth Circuit affirmed the District Court’s dismissal, reversing only two claims, and vacated the attorney’s fees award because, in light of the two reversals, CRST could no longer be considered a prevailing party. On remand, the district court again awarded attorney’s fees to CRST because it had prevailed on the merits on other claims. The Eighth Circuit reversed, disagreeing that CRST prevailed on the merits of those claims. The Eighth Circuit's decision conflicted with the decisions of other circuits, and on appeal, the Supreme Court held that a judgment on the merits is not necessary for a defendant to be considered a prevailing party. The Court reasoned that Congress did not intend for defendants to receive attorney’s fees only in the presence of a judgment on the merits. Rather, the Court acknowledged that it had previously interpreted that prevailing defendants may recover when the plaintiff’s claim is frivolous, unreasonable, or groundless. VACATED and REMANDED.