CRST Van Expedited, Inc. v. EEOC, 578 U.S. ___, 136 S. Ct. 1642 (2016)
The EEOC filed suit against CRST (a trucking company) alleging that over 250 female employees and prospective employees had been subjected to sexual harassment. However, the district court dismissed all of the claims on various grounds, including that the EEOC had not adequately investigated or attempted to conciliate its claims on the employees’ behalf before filing suit. The district court then granted CRST more than $4 million in prevailing-party attorney’s fees. On appeal the United States Court of Appeals for the Eighth Circuit reversed the dismissal of only two claims, which led it to vacate without prejudice the attorney’s fees award. On remand, the EEOC settled one of the reversed claims and withdrew the other. The district court again awarded CRST more than $4 million in attorney’s fees. On appeal, the Eighth Circuit reversed, holding that a Title VII defendant can be a “prevailing party” only by obtaining a ruling on the merits. In this opinion, the United States Supreme Court vacated the Eighth Circuit’s judgment, holding that a favorable ruling on the merits is not a necessary predicate to finding that a defendant is a prevailing party.