## Facts

- John Cole, a member of the Seafarers International Union, introduced resolutions at a union meeting criticizing union leadership and policies.
- The union later expelled Cole under an internal rule barring “deliberate or malicious vilification” of union officers in performing their duties.
- After exhausting internal union remedies, Cole sued in federal court under LMRDA § 102, alleging the expulsion violated his speech rights under LMRDA § 101(a)(2).
- The district court temporarily enjoined the expulsion and later, after trial, permanently reinstated Cole, denied damages, and awarded $5,500 in attorney’s fees based on equitable authority and the benefit to the membership.
- The court of appeals affirmed the fee award; union officers sought Supreme Court review limited to the propriety of attorney’s fees.

## Issues

1. Whether a federal court may award attorney’s fees to a successful LMRDA § 102 plaintiff under inherent equitable powers when the litigation confers a substantial benefit on the union and its members.
2. Whether LMRDA § 102’s authorization of “such relief (including injunctions) as may be appropriate” permits or precludes attorney’s fee awards.
3. Whether the district court abused its discretion by awarding $5,500 in attorney’s fees despite denial of damages.

## Decision

- The Supreme Court affirmed.
- A successful LMRDA § 102 plaintiff may recover attorney’s fees under the court’s equitable power when the suit confers a substantial benefit on the union membership.
- LMRDA § 102 does not bar fee awards; its remedial language is broad and compatible with equitable fee shifting in appropriate cases.
- The district court did not abuse its discretion in awarding $5,500 in fees where the plaintiff obtained reinstatement and vindicated statutory speech rights that protect union democracy.

## Legal Principles

- Under the American Rule, parties ordinarily bear their own fees, but federal courts may award fees under recognized equitable exceptions.
- The “common benefit” doctrine permits fee awards when litigation produces a substantial, nonmonetary benefit for an identifiable group and it is fair to spread costs among beneficiaries (including through an organization that represents them).
- Successful enforcement of LMRDA member speech rights can constitute a substantial benefit to the union and its membership by protecting internal democratic governance and deterring retaliatory discipline.
- Statutory authorization of “appropriate” relief may include equitable attorney’s fee awards when necessary to effectuate the statute’s enforcement scheme and purposes.

## Conclusion

The Court held that attorney’s fees may be awarded in LMRDA § 102 actions under equitable “common benefit” principles when a member’s successful suit protects speech rights in a way that benefits the union membership generally, and it upheld the particular fee award as a proper exercise of discretion.


Hall v. Cole, 412 U.S. 1 (1973)