Summary
The Supreme Court held that a plaintiff who obtains no damages, injunction, declaratory judgment, settlement, or other relief is not a prevailing party entitled to attorney's fees under 42 U.S.C. § 1988. A favorable judicial statement of law in litigation that ultimately results in judgment against the plaintiff does not constitute sufficient relief. The Court also held that the plaintiff could not qualify as a prevailing party based on a later regulatory amendment because he obtained no redress from that amendment.
Topics
Practice areas
Questions Presented
- Whether a plaintiff who receives no damages, injunction, declaratory judgment, settlement, or other relief can qualify as a prevailing party under 42 U.S.C. § 1988 based on a favorable judicial statement of law.
- Whether the amendment of Pennsylvania prison regulations could make Helms a prevailing party under a catalyst theory when he obtained no redress from the amendment.
Holdings
- A plaintiff must receive at least some relief on the merits of the claim to qualify as a prevailing party under § 1988. A favorable judicial statement of law in litigation that ultimately results in judgment against the plaintiff is not sufficient.
- Helms could not qualify as a prevailing party based on the amendment of Directive 801 because the amendment provided him no redress and did not make him a prevailing party retroactively.
Key quotations
“Respect for ordinary language requires that a plaintiff receive at least some relief on the merits of his claim before he can be said to prevail.” (760)
“We conclude that a favorable judicial statement of law in the course of litigation that results in judgment against the plaintiff does not suffice to render him a “prevailing party.”” (763)
Factual background
After a prison riot, inmate Aaron Helms was placed in administrative segregation and later convicted of misconduct based principally on an officer's report of an unidentified informant's testimony. He sued Pennsylvania prison officials under § 1983, alleging due process violations and seeking damages, declaratory and injunctive relief, and expungement of his disciplinary record. The officials obtained summary judgment based on qualified immunity, and Helms received no damages, injunction, declaratory judgment, expungement, settlement, or other relief. During the litigation, Pennsylvania amended its prison regulations concerning confidential-source information in disciplinary proceedings.
Procedural history
Helms brought a § 1983 action alleging due process violations arising from his administrative segregation and prison misconduct conviction. The District Court initially entered summary judgment against him; the Third Circuit reversed in part, and the Supreme Court later held that the segregation procedures satisfied due process. On remand, the District Court granted summary judgment for the officials based on qualified immunity, and the Third Circuit affirmed that judgment while reversing the denial of attorney's fees and remanding for consideration of a catalyst theory. The Supreme Court granted certiorari and reversed.