Attorneys' fees in environmental citizen suits enable private citizens to enforce environmental legislation. First introduced in the federal Clean Air Act, attorney s fee provisions are now included in virtually all environmental legislation. Without provisions for the award of attorneys' fees, legislation allowing for private citizen enforcement would be practically meaningless. Attorneys' fees provisions typically allow for prevailing parties to be awarded attorneys' fees when it is "appropriate. " The appropriateness standard has routinely justified awarding attorneys' fees to prevailing plaintiffs, while defendants have commonly been awarded fees only when a suit is deemed frivolous, harassing, or without merit. This Comment explores how prevailing defendants continue to rely on the language of the applicable statutes to argue that they are entitled to attorneys' fees as prevailing parties, and how the principles of equity can provide a better basis for awarding attorneys' fees to prevailing defendants.