Buckhannon Board and Care Home v. West Virginia Department of Health and Human Resources
United States Supreme Court
532 U.S. 598 (2001)
West Virginia (defendant) ordered Buckhannon Board and Care Home (plaintiff) to close its assisted-living facility for failing a "self-preservation" fire-safety requirement; Buckhannon sued claiming the requirement violated the Fair Housing Amendments Act and the ADA, and West Virginia agreed to stay enforcement pending litigation. Before any judgment, the state legislature independently eliminated the self-preservation requirement, mooting the case; the district court dismissed as moot, and when Buckhannon sought attorney's fees as a "prevailing party" under the catalyst theory (arguing its lawsuit caused the legislative change), the district court denied fees, following the Fourth Circuit's rejection of that theory.
Whether a plaintiff is a prevailing party entitled to attorney's fees when its lawsuit causes the defendant to voluntarily change its conduct, without any court-ordered judgment or consent decree establishing that outcome.