## Facts

- Victor Barrios, a paraplegic who used an athletic wheelchair, served as an assistant baseball coach at Westminster High School within the California Interscholastic Federation (CIF) Southern Section for four seasons.
- His coaching duties included on-field activities such as serving in the first- or third-base coach’s box and visiting the pitcher’s mound during games.
- CIF and its Southern Section applied safety-based rules that barred Barrios, because of his wheelchair use, from coaching on the field during games.
- Barrios sued CIF and CIF Southern Section alleging disability discrimination, including under Title II of the Americans with Disabilities Act (ADA) and parallel state-law provisions.
- The parties executed a written settlement agreement under which CIF/CIF Southern Section agreed (1) not to exclude Barrios from on-field baseball coaching and (2) to pay $10,000 in compensatory damages.
- After settlement, Barrios moved for attorney’s fees and costs as the prevailing party; the district court denied the motion.

## Issues

1. Whether a plaintiff who obtains a written settlement agreement providing compensatory damages and specific non-exclusion relief qualifies as a “prevailing party” eligible for attorney’s fees under the ADA and related fee-shifting statutes after *Buckhannon*.
2. Whether the settlement reflected a material alteration of the parties’ legal relationship with sufficient judicial sanction to satisfy the prevailing-party standard.

## Decision

- The Ninth Circuit reversed the district court’s denial of attorney’s fees and costs.
- The court held Barrios was a prevailing party because the settlement imposed binding, enforceable obligations on defendants and provided monetary relief.
- The court concluded the settlement, reached in the course of federal litigation and tied to the case’s dismissal, carried sufficient judicial sanction under *Buckhannon*.
- The case was remanded for calculation of reasonable attorney’s fees and costs.

## Legal Principles

- A “prevailing party” under federal fee-shifting statutes must obtain a material alteration of the legal relationship of the parties that bears judicial sanction; voluntary, nonbinding changes triggered by litigation are insufficient.
- A settlement can support prevailing-party status when it creates enforceable obligations and is sufficiently connected to the court’s disposition of the action to satisfy the judicial-sanction requirement.
- Monetary relief and binding injunctive-type commitments in a settlement are strong indicators of a material alteration in the parties’ legal relationship.
- *Buckhannon* rejects prevailing-party status based solely on the catalyst theory, but does not bar fee awards where the plaintiff secures enforceable relief through a court-connected settlement.

## Conclusion

The Ninth Circuit held that Barrios’s settlement—requiring non-exclusion from on-field coaching and payment of $10,000—materially changed the parties’ legal relationship with adequate judicial sanction, making him a prevailing party entitled to reasonable attorney’s fees and costs.


Barrios v. California Interscholastic Federation, 277 F.3d 1128 (9th Cir. 2002)