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Newman v. Piggie Park Enterprises, Inc.

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


Facts

Newman and others (plaintiffs) brought a class-action suit against Piggie Park Enterprises, Inc. (Piggie Park) (defendant) under Title II of the Civil Rights Act of 1964 (Title II), 42 U.S.C. § 2000a-3(a), to enjoin racial discrimination at five drive-in restaurants and one sandwich shop owned by Piggie Park. The district court found, on undisputed evidence, that Piggie Park had discriminated against African-Americans at all six restaurants. However, the district court found that Title II did not apply to drive-in restaurants, and thus only enjoined discrimination at the sandwich shop. The court of appeals reversed the denial of the injunction against the drive-in restaurants, finding that Title II applied to drive-in restaurants. On remand to the district court, the court of appeals instructed the district court to award attorneys’ fees to the plaintiffs, but only to the extent that Piggie Park’s defenses had been advanced for the purpose of delay and not in good faith. The plaintiffs appealed, arguing that the court of appeals had used an improper standard for awarding attorneys’ fees.

Rule of Law

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Issue

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Holding and Reasoning (Per curiam)

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  • A "yes" or "no" answer to the question framed in the issue section;
  • A summary of the majority or plurality opinion, using the CREAC method; and
  • The procedural disposition (e.g. reversed and remanded, affirmed, etc.).

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