Background
LaSandra Price, who uses a wheelchair due to Parkinson’s disease, visited Family Dollar #8920 in Fontana, California four times between August and September 2021. On each visit, she encountered accessibility barriers violating the Americans with Disabilities Act: poorly marked disabled parking spaces, uneven walkways, narrow aisles, and non-compliant signage. She sued the store and its owner, Wael Diab.
The defendants never responded to her complaint. Price moved for default judgment and injunctive relief requiring the store to comply with ADA accessibility requirements within 180 days. The district court granted both the default judgment and injunction, ordering the defendants to fix parking spaces, walkways, and signage to achieve ADA compliance.
Price then requested $9,364 in attorney’s fees under 42 U.S.C. § 12205. The district court denied the motion, holding that Price was not a “prevailing party” because the injunction “does not require Defendants to do anything that they are not already required to do under federal law.” The court reasoned that an order merely mandating legal compliance could not confer prevailing party status.
The Court’s Holding
The Ninth Circuit reversed, holding that Price was a prevailing party entitled to attorney’s fees. Applying the Supreme Court’s test from Farrar v. Hobby, the court held that a plaintiff prevails when “actual relief on the merits of her claim materially alters the legal relationship between the parties by modifying the defendant’s behavior in a way that directly benefits the plaintiff.” Here, Price’s injunction forced the defendants to undertake specific improvements at the store, directly benefiting her accessibility rights.
The court rejected the district court’s reasoning that an injunction requiring compliance with existing law cannot confer prevailing party status. The court explained that this misread Fischer v. SJB-P.D. Inc., which actually rejected precisely this argument. Fischer held that the relevant question is whether the plaintiff obtained an enforceable judgment or settlement, not whether the defendant’s underlying duty changed. An injunction is a judicially enforceable order that subjects the defendant to further court enforcement if violated—a material alteration of the legal relationship.
The Ninth Circuit further held that injunctive relief without damages is sufficient for prevailing party status, and that a default judgment constitutes an enforceable judgment on the merits. The court noted that adopting the district court’s logic would eliminate prevailing party status for all permanent injunctions, since injunctions by definition rest on preexisting legal obligations. The Supreme Court rejected similar reasoning in Lefemine v. Wideman, holding that injunctions requiring compliance with law support attorney’s fee awards.
Key Takeaways
- An ADA plaintiff who obtains final injunctive relief, even without monetary damages, is a “prevailing party” eligible for attorney’s fees under § 12205.
- The fact that an injunction merely mandates compliance with existing law does not preclude prevailing party status; the focus is on whether relief materially altered the legal relationship through an enforceable order.
- A default judgment is an enforceable judgment on the merits that qualifies a plaintiff as a prevailing party.
- Courts should consider the quality of legal representation when determining reasonable fee awards, including whether pleadings show diligence and are tailored to the specific case.
Why It Matters
This decision clarifies an important ambiguity in ADA litigation: whether plaintiffs who settle or obtain injunctions without damages can recover attorney’s fees. By holding that injunctive relief creates prevailing party status, the court removes a barrier to fee recovery that some defendants had exploited—agreeing to comply with accessibility requirements in exchange for fighting the fee motion. The decision likely encourages more ADA cases since counsel now have clearer authority to pursue fees even when damages are unavailable.
The ruling also provides important guidance on what constitutes a “material alteration” of the legal relationship. Federal courts had split on whether mandatory injunctions based on preexisting duties truly altered parties’ relationships. The Ninth Circuit’s holding—that an enforceable court order constitutes material alteration regardless of preexisting legal obligations—aligns with recent Supreme Court precedent and should reduce district court confusion on this issue.