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14-1375 CRST VAN EXPEDITED, INC. V. EEOC DECISION BELOW: 774 F.3d 1169 CERT. GRANTED 12/4/2015 QUESTION PRESENTED: Whether a dismissal of a Title VII case, based on the Equal Employment Opportunity Commission's total failure to satisfy its pre-suit investigation, reasonable cause, and conciliation obligations, can form the basis of a attorney's fee award to the defendant under 42 U.S.C. § 2000e-5(k)? LOWER COURT CASE NUMBER: 13-3159
The U.S. Supreme Court case CRST Van Expedited, Inc. v. Equal Employment Opportunity Commission (EEOC) in 2015 revolved around the issue of whether a defendant needs to obtain a favorable ruling on the merits to be considered a "prevailing party" for purposes of awarding attorney's fees under Title VII of the Civil Rights Act of 1964. The EEOC had sued CRST, alleging that it violated Title VII by tolerating sexual harassment against female employees but failed to prove its claim and did not establish liability for any alleged unlawful employment practices after years of litigation. Consequently, CRST sought reimbursement for legal costs as the prevailing party in court proceedings. In an unanimous decision, the Supreme Court ruled that defendants do not need to win on substantive grounds or secure a judgment addressing the lawsuit’s merits in order to qualify as “prevailing parties” eligible for attorney’s fee awards under federal law; rather they can also prevail if they manage to avoid liability due their opponent's failure meet procedural requirements such as conducting proper pre-suit investigation and conciliation efforts.
In the dissenting opinion for CRST Van Expedited, Inc. v. Equal Employment Opportunity Commission (EEOC), Justice Ruth Bader Ginsburg argued that a defendant cannot be deemed a "prevailing party" eligible to recover attorney's fees unless the court's judgment alters the legal relationship between parties in a way that directly benefits the defendant. She disagreed with awarding CRST its legal fees because EEOC’s claim was not frivolous, unreasonable or groundless as required by Title VII of Civil Rights Act 1964 to justify fee shifting from plaintiff to defendant. The dismissal of EEOC’s claims were largely procedural and did not address their merits; hence, she believed it didn't meet this standard. Furthermore, she criticized majority decision for undermining Congress' intent behind Title VII which is meant to encourage plaintiffs like EEOC who act on behalf of alleged victims of workplace discrimination.