Lexplug logoLexplug

Newman v. Piggie Park Enterprises, Inc

Supreme Court of United States
390 U.S. 400 (1968)
ELI5:

Rule of Law:

A plaintiff who succeeds in obtaining an injunction under Title II of the Civil Rights Act of 1964 should ordinarily recover an attorney's fee unless special circumstances would render such an award unjust.


Facts:

  • Petitioners, a group of African Americans, were subjected to racial discrimination at five drive-in restaurants and a sandwich shop in South Carolina.
  • All six establishments were owned and operated by the respondents, Piggie Park Enterprises, Inc.
  • The respondents had a policy and practice of refusing service to African Americans because of their race.
  • The fact that the respondents engaged in this racial discrimination was undisputed at trial.

Procedural Posture:

  • Petitioners filed a class action lawsuit against respondents in the U.S. District Court, seeking to enjoin racial discrimination at six restaurants.
  • The District Court found discrimination at all six locations but only granted an injunction for the sandwich shop, holding that Title II did not apply to the drive-in restaurants.
  • Petitioners appealed the denial of the injunction for the five drive-in restaurants to the U.S. Court of Appeals for the Fourth Circuit.
  • The Court of Appeals reversed the District Court, holding that Title II did cover the drive-ins and ordered an injunction for all six locations.
  • In its remand order, the Court of Appeals instructed the District Court to award attorney's fees only if it found that the respondents' defenses had been advanced in bad faith.
  • The petitioners then successfully petitioned the U.S. Supreme Court for a writ of certiorari to review the standard for awarding attorney's fees.

Locked

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does the attorney's fee provision of Title II of the Civil Rights Act of 1964 limit awards to prevailing plaintiffs only to cases where the defendant's defenses were advanced in bad faith for the purposes of delay?


Opinions:

Majority - Per Curiam

No. The attorney's fee provision of Title II was not intended merely to penalize defendants who advance bad-faith defenses, but rather to encourage individuals injured by racial discrimination to seek judicial relief. When a plaintiff sues under Title II, they act as a 'private attorney general,' vindicating a congressional policy of the highest priority. If such plaintiffs were routinely forced to bear their own legal costs, few would be able to afford to bring these important suits, thus frustrating the enforcement of the Act. Therefore, a successful plaintiff is presumptively entitled to recover attorney's fees, and they should be awarded unless special circumstances would make it unjust.



Analysis:

This decision establishes a strong presumption in favor of awarding attorney's fees to prevailing plaintiffs in Title II discrimination cases. It solidifies the 'private attorney general' theory, recognizing that private litigants are the primary enforcement mechanism for this apect of the Civil Rights Act. By shifting the standard from a punitive one (punishing bad faith) to an incentive-based one (encouraging lawsuits), the Court made it far more financially viable for individuals to challenge discrimination, thereby promoting broader compliance with the law. This standard has been influential in the interpretation of similar fee-shifting statutes in other areas of federal law.

🤖 Gunnerbot:
Query Newman v. Piggie Park Enterprises, Inc (1968) directly. You can ask questions about any aspect of the case. If it's in the case, Gunnerbot will know.
Locked
Subscribe to Lexplug to chat with the Gunnerbot about this case.

Unlock the full brief for Newman v. Piggie Park Enterprises, Inc