CRST Van Expedited, Inc. v. Equal Employment Opportunity Comm’n, 578 U.S. ___ (2016)


Issues: , ,

Intro

Contents

NOTE:?Where it is feasible, a syllabus (headnote) will be released, as is being done in connection with this case, at the time the opinion is issued.The syllabus constitutes no part of the opinion of the Court but has been prepared by the Reporter of Decisions for the convenience of the reader.See United States v. Detroit Timber & Lumber Co., 200 U.?S. 321 .

SUPREME COURT OF THE UNITED STATES

CRST VAN EXPEDITED, INC. v. EQUAL EMPLOYMENT OPPORTUNITY COMMISSION

certiorari to the united states court of appeals for the eighth circuit

No. 14?1375.?Argued March 28, 2016?Decided May 19, 2016

Syllabus

Petitioner CRST, a trucking company using a system under which two employees share driving duties on a single truck, requires its drivers to graduate from the company?s training program before becoming a certified driver. In 2005, new driver Monika Starke filed a charge with the Equal Employment Opportunity Commission (Commission), alleging that she was sexually harassed by two male trainers during the road-trip portion of her training. Following the procedures set out in Title VII of the Civil Rights Act of 1964, see 42 U.?S.?C. ?2000e?5(b), the Commission informed CRST about the charge and investigated the allegation, ultimately informing CRST that it had found reasonable cause to believe that CRST subjected Starke and ?a class of employees and prospective employees to sexual harassment? and offering to conciliate. In 2007, having determined that conciliation had failed, the Commission, in its own name, filed suit against CRST under ?706 of Title VII. During discovery, the Commission identified over 250 allegedly aggrieved women. The District Court, however, dismissed all of the claims, including those on behalf of 67 women, which, the court found, were barred on the ground that the Commission had not adequately investigated or attempted to conciliate its claims on their behalf before filing suit. The District Court then dismissed the suit, held that CRST is a prevailing party, and invited CRST to apply for attorney?s fees. CRST filed a motion for attorney?s fees. The District Court awarded the company over $4 million in fees. The Eighth Circuit reversed the dismissal of only two claims?on behalf of Starke and one other employee?but that led it to vacate, without prejudice, the attorney?s fees award. On remand, the Commission settled the claim on behalf of Starke and withdrew the other. CRST again sought attorney?s fees, and the District Court again awarded it more than $4 million, finding that CRST had prevailed on the claims for over 150 of the allegedly aggrieved women, including the 67 claims dismissed because of the Commission?s failure to satisfy its presuit requirements. The Eighth Circuit reversed and remanded once more. It held that a Title VII defendant can be a ?prevailing party? only by obtaining a ?ruling on the merits,? and that the District Court?s dismissal of the claims was not a ruling on the merits.

Held:?A favorable ruling on the merits is not a necessary predicate to find that a defendant is a prevailing party. Pp.?11?16.

(a)?Common sense undermines the notion that a defendant cannot ?prevail? unless the relevant disposition is on the merits. A plaintiff seeks a material alteration in the legal relationship between the parties. But a defendant seeks to prevent an alteration in the plaintiff?s favor, and that objective is fulfilled whenever the plaintiff?s challenge is rebuffed, irrespective of the precise reason for the court?s decision, i.e., even if the court?s final judgment rejects the plaintiff?s claim for a nonmerits reason. There is no indication that Congress intended that defendants should be eligible to recover attorney?s fees only when courts dispose of claims on the merits. Title VII?s fee-shifting statute allows prevailing defendants to recover whenever the plaintiff?s ?claim was frivolous, unreasonable, or groundless.?Christiansburg Garment Co. v. EEOC, 434 U.?S. 412 . Congress thus must have intended that a defendant could recover fees expended in frivolous, unreasonable, or groundless litigation when the case is resolved in the defendant?s favor, whether on the merits or not. Christiansburg itself involved a defendant?s request for attorney?s fees in a case where the District Court had rejected the plaintiff?s claim for a non-merits reason. Various Courts of Appeals likewise have applied the Christiansburg standard when claims were dismissed for nonmerits reasons. Pp.?11?14.

(b)?The Court declines to decide the argument, raised by the Commission for the first time during the merits stage of this case, whether a defendant must obtain a preclusive judgment in order to prevail. The Commission?s failure to articulate its preclusion theory earlier has resulted in inadequate briefing on the issue, and the parties dispute whether the District Court?s judgment was in fact preclusive. The Commission also submits that the Court should affirm on the alternative ground that, even if CRST is a prevailing party, the Commission?s position that it had satisfied its presuit obligations was not frivolous, unreasonable, or groundless. These matters are left for the Eighth Circuit to consider in the first instance. It is not this Court?s usual practice to adjudicate either legal or predicate factual questions in the first instance, see Adarand Constructors, Inc. v. Mineta, 534 U.?S. 103 , and that is the proper course here, given the extensive record in this case and the Commission?s change of position between the certiorari and merits stages. Pp.?14?16.

774 F.?3d 1169, vacated and remanded.

Kennedy, J., delivered the opinion for a unanimous Court. Thomas, J., filed a concurring opinion.