An award of attorneys fees to plaintiffs in a Medicaid action brought under § 1983 is reversed because the plaintiffs were not a "prevailing party" as newly defined by the U.S. Supreme Court. Chambers, et al. v. Ohio Dept. of Human Services, et al. (U.S. Ct. App., 6th Cir., Nos. 00-3354/3355, Dec. 11, 2001).
Plaintiffs Robert and Jean Chambers and Lauren and Sarah Holland brought an action under § 1983 challenging Ohio's use of the "income first" rule and the Department of Human Services' notice procedures for amending the community spouse's resource allowance. The district court ruled in the plaintiffs' favor, a decision that the Sixth Circuit Court of Appeals reversed on appeal. See Chambers v. Ohio Dep't of Human Servs., 145 F.3d 793 (6th Cir. 1998). But before the district court had entered its order on remand, the Department changed its regulations in ways that the plaintiffs viewed as beneficial to their cause.
On the premise that they had secured some of the benefits they were seeking, the plaintiffs moved the district court for attorneys fees under the Civil Rights Attorney's Fees Awards Act of 1976, which allows a district court in a § 1983 action to award attorneys fees to "the prevailing party." The district court granted the motion, finding that plaintiffs were a "prevailing party" under the "catalyst" theory that a plaintiff who receives some of the relief sought in a lawsuit--whether through settlement or voluntary action taken by the defendant--can be a prevailing party, even in the absence of a formal judgment.
The U.S. Court of Appeals for the Sixth Circuit reverses in light of a Supreme Court opinion that was issued after the parties had completed their briefs. In the opinion, Buckhannon Bd. & Care Home, Inc. v. W. Virginia Dept. of Health and Human Resources--- U.S. ---, 121 S. Ct. 1835 (2001), the Court concluded that to "prevail," and thus become eligible for attorneys fees, a party must have obtained "a judicially sanctioned change in the legal relationship of the parties." The Court categorically rejected the catalyst theory as a permissible basis for awarding attorney's fees. Since the change in the legal relationship between the plaintiffs and the Department was not "judicially sanctioned," the court reverses the district court's award of attorneys fees.
For the full-text of this decision, click here.
Click here for a related case, In re Application of Auguste.
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