Does the term "prevailing party" in 42 U.S.C. § 1988(b) include a party who is awarded a preliminary injunction if the case becomes moot before final judgment? Specifically, does such a party qualify for an award of attorney's fees when no final judgment on the merits is reached? The Court must determine if temporary injunctive relief, rendered permanent by external events rather than a judicial order, satisfies the statutory requirement for fee eligibility.

• Preliminary injunctions do not conclusively resolve legal disputes on the merits and therefore cannot confer "prevailing party" status.
• Under 42 U.S.C. § 1988(b), a party only prevails when there is a judicially sanctioned, enduring change in the legal relationship between the parties.
• External events that render a case moot do not transform a transient preliminary order into a conclusive adjudication of rights.

• A respondent who obtains a preliminary injunction that provides meaningful relief and is never reversed has successfully maintained their claim "at the end" of the litigation.
• The statutory purpose of 42 U.S.C. § 1988(b) is to encourage attorneys to file civil rights actions for vulnerable people, which should include those who secure interim relief.
• A categorical rule against fees for preliminary injunctions creates perverse incentives for government petitioners to strategically moot cases to avoid paying fees.

• The Court held that respondents who obtain only preliminary injunctive relief before a case becomes moot do not qualify as "prevailing parties" under 42 U.S.C. § 1988(b).
• Relying on *Alyeska Pipeline Service Co. v. Wilderness Society*, the Court noted that under the "American Rule," attorney's fees require express statutory authorization.
• The Court treated "prevailing party" as a legal term of art, citing Black's Law Dictionary and Ballentine's Law Dictionary to define it as one who successfully maintains a claim when the matter is finally resolved or "set at rest."
• It reasoned that preliminary injunctions are transient and designed only to preserve the status quo (*University of Tex. v. Camenisch*) based on a "likelihood of success" rather than a conclusive determination of merits (*Winter v. Natural Resources Defense Council, Inc.*).
• The Court applied the test from *Texas State Teachers Assn. v. Garland Independent School District*, which requires that a party obtain enduring judicial relief that materially alters the legal relationship between the parties.
• Invoking *Buckhannon Board & Care Home, Inc. v. West Virginia Dept. of Health and Human Resources* and *Sole v. Wyner*, the Court concluded that any change in the legal relationship must be both "judicially sanctioned" and "enduring."
• The Court specifically held that the enduring nature of the change must itself be judicially sanctioned; external events (such as a legislative repeal) cannot convert a temporary victory into a lasting one for fee purposes.
• The Court rejected the argument that 42 U.S.C. § 1988(b) allows fees for interim relief unless such relief is conclusive and enduring, distinguishing this from the "substantially prevailed" standard in the Freedom of Information Act (5 U.S.C. § 552(a)(4)(E)).