Owner-Operator Independent Drivers Ass'n v. Swift Transportation Co.

Swift Transportation' Co. (“Swift”) appeals the district court’s award of attorney’s fees to Owner-Operator Independent Drivers Association, Inc. and certain owner operators (collectively “OOIDA”), pursuant to 49 U.S.C. § 14704 (e). OOIDA obtained a declaratory judgment against Swift declaring that leases Swift used prior to 2003 (“Old Form Leases”) violated the Truth in Leasing Act. Swift contends that (1) this declaratory judgment does not satisfy the requirement that OOIDA must be a prevailing party to be entitled to attor ney’s fees; and (2) the district court did not have the authority under 49 U.S.C. § 14704 (a) to enter a declaratory judgment. We affirm.

To be entitled to attorney’s fees under 49 U.S.C. § 14704 (e), OOIDA must be a prevailing party in the underlying litigation. Fulfillment Servs. Inc. v. United Parcel Serv., Inc., 528 F.3d 614, 623-24 (9th Cir.2008). In order to be a prevailing party, OOIDA must satisfy three requirements. First, OOIDA “must obtain an enforceable judgment against the defendant from whom fees are sought, or comparable relief through a consent decree or settlement.” Farrar v. Hobby, 506 U.S. 103, 111 , 113 S.Ct. 566 , 121 L.Ed.2d 494 (1992)…