Christianburg Garment Co. v. Equal Employment Opportunity Commission

In Christianburg Garment Co. v. Equal Employment Opportunity Commission, 434 U.S. 412, 417, 98 S.Ct. 694, 698, 54 L.Ed.2d 648 (1978), the Supreme Court noted that under the attorneys' fees provision of Title VII of the Civil Rights Act, 42 U.S.C. Sec. 2000e-5(k) (1976), attorneys' fees should be awarded to a prevailing plaintiff in all but special circumstances. The Court held, however, that a prevailing defendant should be awarded attorneys' fees only "upon a finding that the plaintiff's action was frivolous, unreasonable, or without foundation, even though not brought in subjective bad faith." Id. at 421, 98 S.Ct. at 700. In Christiansburg Garment Co. v. EEOC, 434 U.S. 412 (1978), the Supreme Court set out the standard basis for awarding attorney fees to prevailing defendants in civil rights cases. The Court stated that "a plaintiff should not be assessed his opponent's attorney's fees unless a court finds that his claim was frivolous, unreasonable, or groundless, or that the plaintiff continued to litigate after it clearly became so." Id. at 422. The Supreme Court held that a plaintiff is subject to an assessment of attorney's fees if the court finds his claims are frivolous, unreasonable or without foundation or it becomes clear that such is the case and the plaintiff continues to litigate the claim. The Supreme Court set the standard for awarding attorney's fees to prevailing defendants in Title VII litigation. Under the Christiansburg standard, a prevailing defendant is entitled to attorney's fees only when the plaintiff's claim "was frivolous, unreasonable, or groundless, or ... the plaintiff continued to litigate after it clearly became so." Id. at 422, 98 S.Ct. at 701. The Supreme Court articulated the criteria that govern the award of attorney's fees to a prevailing defendant in a civil rights action. The Court stated: a district court may in its discretion award attorney's fees to a prevailing defendant in a Title VII case upon a finding that the plaintiff's action was frivolous, unreasonable, or without foundation, even though not brought in subjective bad faith. Id. at 421. In other language the Court stated: a plaintiff should not be assessed his opponent's attorney's fees unless a court finds that his claim was frivolous, unreasonable, or groundless, or that the plaintiff continued to litigate after it clearly became so. Id. at 422. In Christiansburg Garment Company v. The E.E.O.C., 434 U.S. 412, 98 S.Ct. 694, 54 L.Ed.2d 648 (1978), the Supreme Court held that a prevailing defendant in a Title VII action may be awarded attorney's fees "upon a finding that the plaintiff's action was frivolous, unreasonable, or without foundation, even though not brought in subjective bad faith," or "that the plaintiff continued to litigate after it clearly became so." Id. at 421, 422, 98 S.Ct. at 700, 701. In Christianburg Garment Co. v. EEOC, 434 U.S. 412, 98 S.Ct. 694, 54 L.Ed.2d 648 (1978), the Supreme Court set the standards for awarding attorneys' fees to defendants in Title VII actions. The attorneys' fee award provision of Title VII allows attorneys' fees only to a prevailing party, and has been interpreted to require an award of attorneys' fees to prevailing plaintiffs in all but special circumstances. 434 U.S. at 417, 98 S.Ct. at 698. But, the Court found that different considerations govern an award of fees to defendants, and that, therefore, a district court may exercise its discretion to award attorneys' fees to a prevailing defendant only "upon a finding that the plaintiff's action was frivolous, unreasonable, or without foundation, even though not brought in subjective bad faith." 434 U.S. at 421, 98 S.Ct. at 700 The Court then stated its reasons for treating plaintiffs and defendants differently for purposes of awarding attorneys' fees: No matter how honest one's belief that he has been the victim of discrimination, no matter how meritorious one's claim may appear at the outset, the course of litigation is rarely predictable. Decisive facts may not emerge until discovery or trial. The law may change or clarify in the midst of litigation. Even when the law or the facts appear questionable or unfavorable at the outset, a party may have an entirely reasonable ground for bringing suit. 434 U.S. at 422, 98 S.Ct. at 700-01.