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United States Third Circuit

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McBride v. International Longshoremen's Association, 13-4260

In this case, appellant Union challenges the district court's order denying its motion for relief from judgment under Federal Rules of Civil Procedure rule 60(b)(5), arguing that the court mistakenly classified appellee Knight as a prevailing party and wrongly awarded him attorneys fees, including costs and post-judgment fees. In the underlying case involving due process and free speech claims brought by Knight, the district court found in favor of Knight, deciding that the Union violated Knight's due process rights. The judgment of the district court awarding Knight attorney's fees is affirmed, where the district court did not abuse its discretion in based its decision to define Knight as a "prevailing party" on his due process and free speech successes from the first hearing in 2006 rather than his defeat in 2013, as under the common benefit doctrine, the district court was required to make such determination based on the point in time that Knight vindicated his Title I rights in a way that was significant to the union members at-large.

Appellate Information

  • Decided 02/19/2015
  • Published 02/19/2015



  • United States Third Circuit


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