Eighth Circuit -- Jane Doe I v. Jeremiah J. Nixon

Winning a preliminary injunction does not suffice to get fees under S1988 even where subsequent adverse holdings were the result of abstention.

Voluntary cessation of threat of prosecution resulting in a finding that the claim was moot is not a victory that would shift costs under S1988.

District court correctly held that fears of future prosecution were speculative.

Jane Doe I  v.  Jeremiah J. Nixon