Christiansburg Garment Co. v. EEOC

E823908

Christiansburg Garment Co. v. EEOC is a 1978 U.S. Supreme Court decision that established the standard for awarding attorney’s fees to prevailing defendants in Title VII civil rights cases, holding they may recover fees only when the plaintiff’s claim is frivolous, unreasonable, or without foundation.

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Christiansburg Garment Co. v. EEOC canonical 1

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Statements (46)

Predicate Object
instanceOf Title VII case
United States Supreme Court case
appliesTo Title VII civil rights actions NERFINISHED
fee-shifting provisions modeled on Title VII
areaOfLaw civil procedure
labor and employment law
category United States Supreme Court cases of the Burger Court NERFINISHED
United States Supreme Court cases on civil rights
United States Supreme Court cases on employment discrimination
citation 434 U.S. 412
54 L. Ed. 2d 648
98 S. Ct. 694
citationStyle Bluebook NERFINISHED
country United States of America
surface form: United States
court Supreme Court of the United States
decisionDate 1978-01-23
decisionType unanimous decision
docketNumber No. 76-662
fullName Christiansburg Garment Company v. Equal Employment Opportunity Commission NERFINISHED
holding A prevailing defendant in a Title VII case may be awarded attorney’s fees only when the plaintiff’s claim was frivolous, unreasonable, or without foundation.
Prevailing plaintiffs and prevailing defendants are not to be treated identically for purposes of attorney’s fee awards under Title VII.
impact adopted by courts in interpreting 42 U.S.C. § 1988 fee-shifting
governs when defendants may recover attorney’s fees in many federal civil rights cases
issue Whether and under what circumstances a prevailing Title VII defendant may be awarded attorney’s fees.
jurisdiction United States of America
surface form: United States
language English
legalEffect binding precedent on federal courts regarding defendants’ attorney’s fees in Title VII cases
legalSubject attorney’s fees
civil rights enforcement
employment discrimination law
lowerCourt United States Court of Appeals for the Fourth Circuit NERFINISHED
majorityOpinionBy Justice Potter Stewart NERFINISHED
petitioner Christiansburg Garment Company NERFINISHED
reasoning Congress intended to encourage meritorious civil rights litigation by plaintiffs and to avoid chilling such suits through routine fee awards to prevailing defendants.
Courts must avoid post hoc reasoning that because a plaintiff did not prevail, the action must have been unreasonable or without foundation.
relatedCase Hughes v. Rowe NERFINISHED
Newman v. Piggie Park Enterprises, Inc. NERFINISHED
relatedConcept fee-shifting
prevailing party
respondent Equal Employment Opportunity Commission NERFINISHED
standardEstablished frivolous, unreasonable, or without foundation standard for prevailing defendants’ attorney’s fees
statuteInterpreted Title VII of the Civil Rights Act of 1964 NERFINISHED
statutoryProvision 42 U.S.C. § 2000e-5(k)
term 1977 Term
vote 9-0
yearDecided 1978

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Civil Rights Attorney’s Fees Awards Act of 1976 keyCase Christiansburg Garment Co. v. EEOC