Buckhannon Board and Care Home, Inc. v. West Virginia Department of Health and Human Resources case brief

Buckhannon Board and Care Home, Inc. v. West Virginia Department of Health and Human Resources case brief summary
532 U.S. 598 (2001)

CASE SYNOPSIS

Petitioners' class action against state respondents was dismissed as moot after the statutory requirement to which petitioners objected was eliminated by amendment. Upon grant of writ of certiorari, petitioners challenged the judgment of the United States Court of Appeals for the Fourth Circuit, which upheld the denial of petitioners' motion for an award of attorney fees.

CASE FACTS
Petitioners alleged that the statutory requirement, that residents of residential board and care homes be capable of moving themselves from situations involving imminent danger, violated the Fair Housing Amendments Act of 1988, 42 U.S.C.S.§ 3601 et seq., and the Americans with Disabilities Act of 1990, 42 U.S.C.S. § 12101 et seq. After the requirement was statutorily eliminated by respondents' legislature, petitioners sought an award of attorney fees as the prevailing party under the statutes.

DISCUSSION

• The United States Supreme Court held that, even though petitioners obtained the relief they sought, statutory attorney fees were precluded since petitioners could not be deemed the prevailing party. 
• Although petitioners' lawsuit brought about the desired voluntary change by respondents, there was no alteration in the legal relationship of the parties and no judgment in favor of petitioners was entered.

OUTCOME

Judgment was affirmed.

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