The Supreme Court on Dec. 15 ordered a federal appeals court to reconsider its ruling denying attorney’s fees to a white man who succeeded in blocking a Biden-era debt-relief program he alleged was racially discriminatory.
The court’s decision in Holman v. Rollins took the form of an unsigned order that was issued without comment. No justices dissented. No oral argument was held in the case.
The petitioner, Robert Holman, previously won a preliminary injunction halting the U.S. Department of Agriculture (USDA) debt-relief program that he argued discriminated on the basis of race. The respondent is USDA Secretary Brooke Rollins.
The Supreme Court case is not about the program itself. It is about whether Holman was entitled to attorney’s fees after being partially successful in his lawsuit by securing a preliminary injunction blocking the program.
The new ruling was issued after the Supreme Court held in Lackey v. Stinnie that partially successful litigants are not entitled to attorney’s fees. The high court found in February that when a litigant wins a preliminary injunction blocking a government action but the case is not finally adjudicated, that litigant is not considered a “prevailing party” entitled to attorney’s fees.
In that case, motorists had sued Virginia over a state law requiring an automatic driver’s license suspension—without notice or a hearing—for anyone who failed to pay court fines or fees. The motorists won a preliminary injunction blocking the law, but afterward, the Virginia General Assembly repealed the law.
Chief Justice John Roberts wrote in that decision that the motorists had not achieved prevailing party status “because preliminary injunctions do not conclusively resolve the rights of parties on the merits.”
A plaintiff who obtains a preliminary injunction “has achieved only temporary success at an intermediary ‘stage of the suit’” before the case is finally decided, Roberts said at the time. The fact that an external event, such as the repeal of a law, ends the litigation does not make the plaintiff a prevailing party, he said.
Holman’s petition describes him as a Caucasian farmer who was not allowed to participate in the debt-relief program under the American Rescue Plan Act of 2021 “solely because of his race.” The USDA “categorically excluded white or Caucasian farmers from government debt relief under the act,” it said.
Deal Struck on Lawsuit
A federal district court approved Holman’s motion for a preliminary injunction blocking the department “from continuing its blatantly discriminatory loan forgiveness program,” the petition said. Congress repealed the program a year later, and Holman entered an agreement with the government to voluntarily dismiss his lawsuit, signing a document that preserved his right to seek attorney’s fees through the federal Equal Access to Justice Act (EAJA).
EAJA allows prevailing parties in lawsuits against the federal government to receive reimbursement for attorney’s fees provided that the government’s position was “not substantially justified.”
The lower courts are divided over how much weight to place on an agency’s allegedly unreasonable pre-litigation conduct, and some federal courts of appeals put “substantial” or “dispositive” weight on that conduct. But in this case, the U.S. Court of Appeals for the Sixth Circuit “did not emphasize the USDA’s discriminatory policies at all,” the petition said.
The circuit court found the government’s position was substantially justified based on the government’s “professionalism in court” and its success in having two related claims dismissed, the petition said.
When Holman sought an order for reimbursement of his attorney’s fees in the lawsuit, a federal district court denied the request, finding that securing the injunction did not make him a “prevailing party” in the suit. A panel of the Sixth Circuit affirmed the denial 2–1 on different grounds, declining to rule on whether Holman was a prevailing party.
Instead, the panel held that even if Holman were to qualify as a prevailing party, the federal government’s position in the case was “substantially justified.” This decision “improperly prioritized the government’s litigation position and nearly ignored the government’s plainly unconstitutional pre-litigation conduct.”
Holman sought a rehearing before the full Sixth Circuit, and the divided court denied his request, the petition said.
Holman asked the Supreme Court to review the lower court ruling that prevented him from recovering attorney’s fees.
“EAJA plays a vital role in ensuring that victims of government discrimination can vindicate their rights in court,” the petition said. “The statute exists to discourage rash, unconstitutional conduct by federal agencies, and to ensure that aggrieved parties are not deterred from challenging such conduct by the prospect of bearing their own litigation costs.”
The federal government urged the Supreme Court not to take up Holman’s appeal, saying that review of the Sixth Circuit’s “substantial-justification holding is not warranted.”
In a brief, U.S. Solicitor General D. John Sauer acknowledged that the Sixth Circuit’s “holding is in at least some tension” with the Trump administration’s decision that it will no longer defend USDA emergency-relief programs that are “essentially indistinguishable” from the one Holman challenged.
Sauer wrote that the Supreme Court’s decision in Lackey v. Stinnie, which had not been issued when the district and appeals courts ruled, “provides a sounder basis for rejecting petitioner’s current request for EAJA fees.”
In its Dec. 15 ruling, the Supreme Court vacated the Sixth Circuit ruling and sent the case back to that court “for further consideration in light of Lackey v. Stinnie.”
Holman’s attorney, William Trachman of the Mountain States Legal Foundation in Lakewood, Colorado, welcomed the decision.
“We’re pleased with the reversal and vacatur of the Sixth Circuit’s opinion, and are considering next steps in light of the order this morning,” Trachman told The Epoch Times.
Department of Justice spokeswoman Natalie Baldassarre told The Epoch Times that her department had no comment on the ruling.
This article by Matthew Vadum appeared Dec. 15, 2025, in The Epoch Times.