Winning an award of attorney fees in civil rights cases just got a little harder.

In a court battle over the modern-day rights to the names of two 1950s doo-wop groups — The Platters and The Coasters — the 3rd U.S. Circuit Court of Appeals voted 12-4 in holding that a plaintiff cannot be deemed the "prevailing party" unless it has secured a "judgment on the merits."

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