James v. City of Boise
United States Supreme Court
136 S. Ct. 685 (2016)
- Written by Heather Whittemore, JD
Facts
In Hughes v. Rowe, 449 U.S. 5 (1980), the United States Supreme Court held that, under 42 U.S.C. § 1988, a prevailing defendant in a § 1983 civil-rights lawsuit may recover attorney’s fees only if the plaintiff’s lawsuit was frivolous, unreasonable, or without foundation. After Hughes was decided, the Idaho Supreme Court granted attorney’s fees to a defendant in a § 1983 lawsuit without first deciding that the plaintiff’s lawsuit was frivolous, unreasonable, or without foundation. The Idaho Supreme Court argued that it was not bound by the United States Supreme Court’s decision in Hughes, because the United States Supreme Court may not limit the discretion of state courts in interpreting federal statutes if the statute does not grant the Court that power. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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