From our private database of 12,700+ case briefs...
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 Department of Health and Human Resources (West Virginia) (plaintiff) ordered that the Buckhannon Board and Care Home’s (Buckhannon) (defendant) assisted living facility be closed when it failed an inspection by the fire marshal’s office for failing to meet West Virginia’s “self-preservation” requirement. This required that all residents be capable of moving themselves from situations involving imminent danger, such as fire. Buckhannon sued, seeking declaratory and injunctive relief that the self-preservation requirement violated the Fair Housing Amendments Act of 1988 (FHAA) and the Americans with Disabilities Act of 1990 (ADA). West Virginia agreed to stay enforcement of the order pending the resolution of the litigation. However, during the course of the litigation the West Virginia legislature eliminated the self-preservation requirement. West Virginia moved to dismiss the case as moot, and the court granted the motion. Buckhannon then requested attorney’s fees, alleging it was the “prevailing party” under FHAA and ADA, and that, under the “catalyst theory,” a defendant is a "prevailing party" if it achieves the desired result because the lawsuit brought about a voluntary change in the plaintiff’s conduct. The district court denied the motion, noting that the Court of Appeals for the Fourth Circuit had previously rejected the catalyst theory.
Rule of Law
Holding and Reasoning (Rehnquist, C.J.)
Concurrence (Scalia, J.)
Dissent (Ginsburg, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 120,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 12,700 briefs, keyed to 172 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.