The US Supreme Court [official website] ruled [opinion, PDF] unanimously Thursday in CRST Van Expedited, Inc v. EEOC [SCOTUSblog materials that Section 706 of Title VII of the Civil Rights Act of 1964 [text] does not require a favorable ruling on the merits for defendant as a prevailing party for the purposes of awarding attorney’s fees. In an 8-0 opinion by Justice Anthony Kennedy, the court vacated the Eighth Circuits’ judgment against attorney’s fees and remanded the decision on three other matters. In his opinion, Kennedy determined [SCOTUSblog analysis] that the Eighth Circuit’s “on the merits” requirement was unnecessary as it was not common sense when plaintiff and defendant have different objectives. In this matter, he stated that a defendant may get what it whats and “prevail even if the court’s final judgement rejects the plaintiffs claim for a non-meritorious reason.” Second, Kennedy found that there was a lack of any indication that Congress intended an “on the merits” requirement and that such a requirement would lead to further litigation and frivolous lawsuits. Justice Clarence Thomas filed a concurring opinion.
The court heard oral arguments [JURIST report] in March. The suit arose from the dismissal of a class-wide Title VII claim that had alleged CRST had allowed female truck drivers to be sexually harassed. CRST claimed that they were entitled to attorneys fees under Section 2003-5(k) [text] of Title VII of the Civil Rights Act of 1964 which provides that a court “in its discretion, may allow the prevailing party, other than the Commission of the United States, a reasonable attorney’s fee as part of the costs, and the Commission and the United States shall be liable for costs the same as a private person.