LaChance v. Commissioner of Correction

Plaintiff, a Massachusetts prison inmate, brought civil rights action claiming that Defendants violated his constitutional right to due process by holding him in a special management unit (SMU) - or solitary confinement - for ten months without a hearing while waiting to reclassify or transfer him. The Supreme Judicial Court held that segregated confinement on awaiting action status for longer than ninety days gives rise to a liberty interest entitling an inmate to notice and a hearing. On remand, the superior court entered declaratory judgment in favor of Plaintiff and awarded him attorney’s fees and costs. Defendants appealed, arguing that Plaintiff was not a prevailing party under 42 U.S.C. § 1988(b) because he had been discharged from SMU detention long before he won any relief, and therefore, the declaratory judgment was moot and did not directly benefit him or materially alter his relationship with Defendants. The Supreme Judicial Court affirmed, holding (1) Plaintiff did qualify as a prevailing party in the circumstances of this case; and (2) the award of fees to Plaintiff was reasonable. View "LaChance v. Commissioner of Correction" on Justia Law