LaChance v. Commissioner of Correction

Summary

The Massachusetts Supreme Judicial Court considered whether a prison inmate was a prevailing party entitled to attorney's fees under the Federal Civil Rights Attorney's Fees Award Act, 42 U.S.C. § 1988(b). The court held that the plaintiff qualified as a prevailing party because the declaratory judgment was not moot when entered, was capable of repetition, and directly benefited him. The court affirmed the award of $28,578.69 in attorney's fees and costs.

Holdings

1. LaChance qualified as a prevailing party because he obtained an enforceable declaratory judgment on the merits that was not moot when entered, directly benefited him, and materially altered his legal relationship with the defendants.
2. The Superior Court did not abuse its discretion by awarding $28,186 in attorney's fees after calculating the lodestar and reducing it by fifty percent to account for LaChance's partial success.
3. LaChance was entitled under § 1988(b) to recover reasonable attorney's fees and costs incurred in defending the Superior Court's fee award on appeal.

Questions Presented

1. Whether LaChance was a prevailing party entitled to attorney's fees under 42 U.S.C. § 1988(b) even though he had been released from the challenged special management unit before declaratory judgment entered.
2. Whether the declaratory judgment was moot when entered and whether it directly benefited LaChance or materially altered his legal relationship with the defendants.
3. Whether the Superior Court abused its discretion in awarding $28,186 in attorney's fees, plus $392.69 in costs.
4. Whether LaChance was entitled to reasonable attorney's fees and costs incurred in defending the fee award on appeal.

Disposition

affirmed