Shelby County v. Lynch, No. 14-5138 (D.C. Cir. 2015)
Annotate this CaseThe County seeks attorneys' fees from the Government under the Voting Rights Act of 1965's (VRA), 52 U.S.C. 10310(e), fee-shifting provision after the County prevailed in a challenge to the constitutionality of the VRA. The court agreed with the district court that the County is not entitled to attorneys’ fees because its lawsuit did not advance any of the purposes that Congress meant to promote by making fees available. Even though the County has based its argument for fees entirely on Newman v. Piggie Park Enterprises, Inc., the district court considered whether the County might also be entitled to fees under the Christiansburg Garment Co. v. EEOC standard, which would allow a fee award only if the Government’s defense of the coverage formula’s constitutionality was frivolous or without foundation. But since the County has never maintained that it could even theoretically obtain fees under that standard, the court did not resolve whether Christiansburg Garment should sometimes apply in cases like this one. The court concluded that it is enough to resolve this fee dispute by holding that the County is not entitled to fees under the only standard it has urged the court to apply. Accordingly, the court affirmed the district court's denial of attorneys' fees.
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