## Facts

- Melene James brought a civil-rights action under 42 U.S.C. § 1983 in Idaho state court against the City of Boise and others.
- The defendants prevailed and sought attorney’s fees under 42 U.S.C. § 1988.
- The Idaho Supreme Court awarded attorney’s fees to the prevailing defendants under § 1988 without finding James’s claims “frivolous, unreasonable, or without foundation.”
- In doing so, the Idaho Supreme Court expressly declined to follow the U.S. Supreme Court’s interpretation of § 1988 in Hughes v. Rowe, reasoning that Supreme Court limits on fee awards did not bind state courts unless written into the statute.
- James sought review, asserting that state courts are bound by the U.S. Supreme Court’s interpretations of federal law.

## Issues

1. Whether state courts are bound by the U.S. Supreme Court’s interpretations of federal statutes when applying those statutes.
2. Whether a state supreme court may award attorney’s fees to a prevailing § 1983 defendant under 42 U.S.C. § 1988 without determining that the plaintiff’s action was “frivolous, unreasonable, or without foundation,” contrary to Hughes v. Rowe.

## Decision

- The U.S. Supreme Court reversed and remanded in a per curiam opinion.
- The Court held that state courts, like federal courts, must follow the U.S. Supreme Court’s authoritative interpretations of federal statutes.
- The Idaho Supreme Court erred by refusing to apply Hughes v. Rowe’s construction of § 1988 and awarding fees under a different standard.
- Because the fee award rested on the state court’s interpretation of federal law and the state court did not award fees under state law, the judgment could not stand.

## Legal Principles

- The U.S. Supreme Court has final authority to interpret federal statutes, and other courts must follow those interpretations.
- Federal law must have a uniform meaning across states; state courts may not give federal statutes divergent constructions.
- Under 42 U.S.C. § 1988, a prevailing defendant in a § 1983 action may recover attorney’s fees only if the plaintiff’s claim was “frivolous, unreasonable, or without foundation,” as stated in Hughes v. Rowe (applying the Christiansburg standard).

## Conclusion

The Supreme Court held that state courts are bound by the Supreme Court’s interpretations of federal statutes and reversed an Idaho fee award made under § 1988 without applying the required “frivolous, unreasonable, or without foundation” standard for prevailing defendants.


James v. City of Boise, 136 S. Ct. 685 (2016)