Thus having ascertained our jurisdiction, we now turn to the merits. Under
42 U.S.C. § 1973l(e), a court “in its discretion, may allow the prevailing party a reasonable attorney's fee” in an action, such as this one, “to enforce the voting guarantees of the fourteenth or fifteenth amendments.” Pursuant to
42 U.S.C. § 1988, a court may make a similar award of fees to a “prevailing party” in a suit to enforce the provisions of
42 U.S.C. § 1983.
Although the statutes commit fee awards to the district court's discretion, Congress has nevertheless made clear that prevailing plaintiffs “should ordinarily recover an attorney's fee unless special circumstances would render such an award unjust.” S.Rep. 925, 94th Cong., 1st Sess. 40 (1975),
reprinted in 1975 U.S.C.C.A.N. 774, 807 (addressing
§ 1973l(e)); S.Rep. 1011, 94th Cong., 2d Sess. 4 (1976),
reprinted in 1976 U.S.C.C.A.N. 5908, 5912 (addressing
§ 1988). In any event, our analysis begins by determining which parties, if any, prevailed.