Alyeska Pipeline Service Co. v. Wilderness Society

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In Alyeska Pipeline Service Co. v. Wilderness Society, 421 U.S. 240 (1975), the U.S. Supreme Court adhered to the American Rule and declined to award attorneys' to the prevailing party in a civil rights action under Section 1983. The Court overturned an award of such fees by the appellate court.

Justice Byron White wrote the opinion for the 5-2 Court. He described the context:

This litigation was initiated by respondents Wilderness Society, Environmental Defense Fund, Inc., and Friends of the Earth in an attempt to prevent the issuance of permits by the Secretary of the Interior which were required for the construction of the trans-Alaska oil pipeline. The Court of Appeals awarded attorneys' fees to respondents against petitioner Alyeska Pipeline Service Co. based upon the court's equitable powers and the theory that respondents were entitled to fees because they were performing the services of a "private attorney general." Certiorari was granted, 419 U.S. 823 (1974), to determine whether this award of attorneys' fees was appropriate. We reverse.

Congress effectively overturned this ruling by passing the Civil Rights Attorney's Fees Awards Act the following year.