Crabtree v. Collins

Summary

The Sixth Circuit held that a prisoner whose § 1983 deliberate indifference claim was dismissed as moot upon his release was not a "prevailing party" entitled to attorney's fees under 42 U.S.C. § 1988. The court ruled that prevailing party status requires a material alteration of the legal relationship through relief on the merits, which was not achieved by the court's appointment of a medical expert or the plaintiff's release upon sentence completion. A "nonfrivolous" claim alone is insufficient to support a fee award under § 1988.

Holdings

1. Crabtree is not a prevailing party because he did not obtain any relief on the merits of his claims, the appointment of a medical expert was not relief sought, and his release was not caused by the lawsuit.

Questions Presented

1. Whether Crabtree is a 'prevailing party' under 42 U.S.C. § 1988.

Disposition

reversed