Crites-Bachert v. Providence Health & Services - Oregon

CourtDistrict Court, D. Oregon
DecidedAugust 22, 2025
Docket3:23-cv-01510
StatusUnknown

This text of Crites-Bachert v. Providence Health & Services - Oregon (Crites-Bachert v. Providence Health & Services - Oregon) is published on Counsel Stack Legal Research, covering District Court, D. Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crites-Bachert v. Providence Health & Services - Oregon, (D. Or. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION

MELANIE CRITES-BACHERT,

Plaintiff, Case No. 3:23-cv-01510-YY v. FINDINGS AND PROVIDENCE HEALTH & SERVICES - RECOMMENDATIONS OREGON,

Defendant.

YOU, Magistrate Judge. FINDINGS Plaintiff Melanie Crites-Bachert brought suit in this court against her former employer, defendant Providence Health & Services, alleging constitutional, statutory, contract, and tort claims based on defendant’s denial of her request for a religious accommodation from the COVID-19 vaccine and resulting revocation of hospital privileges. Am. Compl., ECF 11. The court dismissed all claims with prejudice. Order, ECF 21. Defendant now seeks attorney fees under 42 U.S.C. § 1988 and costs pursuant to Federal Rule of Civil Procedure 54(d). Mot. Att’y Fees, ECF 23. For the reasons stated below, defendant’s motion should be denied. I. Attorney Fees in Civil Rights Actions Generally, courts follow the “American Rule” and require each party in litigation to bear their own expenses regardless of the outcome. Fox v. Vice, 563 U.S. 826, 832 (2011). Congress, however, “deviate[s]” from this general principle and authorizes “shifting fees from one party to another” in certain cases. Id. Congress enacted 42 U.S.C. § 1988 to provide for such fee shifting in civil rights actions. Id. at 832–33. The statute allows the court, “in its discretion,” to award prevailing parties with reasonable attorney fees in civil rights cases brought under 42 U.S.C. § 1983. 42 U.S.C. § 1988(b).

The Supreme Court has noted that such fee shifting in favor of prevailing plaintiffs is warranted because the defendant’s misconduct “created the need for legal action” and a successful plaintiff is “vindicating” a policy that is of great significance to Congress. Fox, 563 U.S. at 833; see generally Harris v. Maricopa Cnty. Superior Ct., 631 F.3d 963, 971 (9th Cir. 2011) (observing that civil rights is a high priority policy and awarding attorney fees in such cases are “in large part” to encourage individuals who suffered from discrimination to seek relief in court). Those policy considerations, however, are not present when the prevailing party is the defendant.1 Christiansburg Garment Co. v. Equal Emp. Opportunity Comm’n, 434 U.S. 412, 418–19 (1978). Defendants may be awarded attorney fees under § 1988, but they face a different

standard. Fox, 563 U.S. at 833; Mitchell v. Off. of Los Angeles Cnty. Superintendent of Sch., 805 F.2d 844, 847 (9th Cir. 1986) (explaining that Congress intended § 1988 to protect defendants from having to litigate claims with no legal or factual basis). “The mere fact that a defendant prevails does not automatically support an award of fees. A prevailing defendant should be awarded attorney’s fees ‘not routinely, not simply because he succeeds, but only where the

1 Defendants “need not obtain a favorable judgment on the merits” to be a prevailing party. CRST Van Expedited, Inc. v. E.E.O.C., 578 U.S. 419, 431 (2016). The Supreme Court reasoned that plaintiffs and defendants “come to court with different objectives” and that for a defendant, “its primary objective” is fulfilled so long as the plaintiff’s claim is “rebuffed, irrespective of the precise reason for the court’s decision.” Id. Moreover, “it would make little sense” that congressional policy of sparing defendants from frivolous claims turned on “the distinction between merits-based and non-merits-based frivolity.” Id. at 432. action brought is found to be unreasonable, frivolous, meritless or vexatious.’” Patton v. Cnty. of Kings, 857 F.2d 1379, 1381 (9th Cir. 1988) (internal citation omitted) (quoting Christiansburg, 434 U.S. at 421). To that end, the Ninth Circuit instructs that fees should only be awarded to defendants in civil rights actions “in exceptional circumstances.” Barry v. Fowler, 902 F.2d 770,

773 (9th Cir. 1990); see Wilson v. Lane Cnty. Sheriff’s Off., No. 6:12-cv-00691-MC, 2015 WL 1058804, at *1 (D. Or. Mar. 6, 2015) (noting that attorney fees under § 1988 are awarded only in exceptional circumstances and when the claims are frivolous, unreasonable or groundless). Accordingly, the Ninth Circuit has held that district courts still retain discretion to deny a defendant’s request for attorney fees in civil rights actions even if the claims are found to be frivolous, unreasonable, or groundless. Thomas v. City of Tacoma, 410 F.3d 644, 651 (9th Cir. 2005) (citing Tang v. State of R.I., Dep’t of Elderly Affs., 163 F.3d 7 (1st Cir. 1998) (“Notwithstanding such a finding [of frivolity], the district court still retains discretion to deny or reduce fee requests after considering all the nuances of a particular case.”)). “An action becomes frivolous when the result appears obvious or the arguments are

wholly without merit.” Galen v. Cnty. of Los Angeles, 477 F.3d 652, 666 (9th Cir. 2007). “A losing § 1983 claim is without merit only if it is ‘groundless or without foundation.’” Gibson v. Off. of Atty. Gen., State of California, 561 F.3d 920, 929 (9th Cir. 2009) (quoting Christiansburg, 434 U.S. at 421); see generally Traver v. Meshriy, 627 F.2d 934, 939 (9th Cir. 1980) (noting “tenuous” claims are not frivolous). Courts must also avoid “the understandable temptation to engage in post hoc reasoning” and recognize that a party may have had a reasonable ground for bringing a lawsuit even if the facts and law were “questionable or unfavorable at the outset.” Christiansburg, 434 U.S. at 421–22. A. Plaintiff’s § 1983 Claims and Allegations of State Action Plaintiff brought claims pursuant to 42 U.S.C. § 1983 alleging that defendant violated various constitutional rights. Am. Compl. ¶¶ 240–57, 261–67, 278–81, ECF 11. Defendant is a private party that operates a hospital system. Id. ¶¶ 1, 142. As a private party, defendant can be

liable under § 1983 only if it was acting under the color of state law. Tsao v. Desert Palace, Inc., 698 F.3d 1128, 1139 (9th Cir. 2012). Thus “a plaintiff must show that ‘the conduct allegedly causing the deprivation of a federal right [was] fairly attributable to the State.’” Id. (quoting Lugar v. Edmondson Oil Co., 457 U.S. 922, 937 (1982)). The court dismissed plaintiff’s § 1983 claims because her pleadings failed to plausibly allege that defendant’s conduct could be attributed to the state. Defendant then filed a motion for an award of attorney fees pursuant to § 1988(b). B.

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