Douglas Burr v. Department of Corrections, 240 A.3d 371

Douglas Burr, serving a lengthy sentence, was placed on Emergency Observation Status and then held in restrictive housing for ~22 months; only 20 days were the product of a disciplinary sanction following a July 2014 hearing.
While in segregation (administrative segregation then ACU) Burr had severely limited privileges; he did not earn good-time credit during the entire segregation period.
Burr sued in Superior Court: Count 1 sought Rule 80C judicial review of the disciplinary decision; Count 2 asserted a 42 U.S.C. § 1983 claim seeking injunctive relief against unconstitutional segregation practices.
The Superior Court vacated the disciplinary finding and (initially) restored good-time credit under Rule 80C, found due-process violations as to segregation practices at trial, but concluded it lacked authority under the Maine Constitution to grant injunctive relief on the § 1983 claim.
The court later clarified it restored good time for the entire 22 months; on appeal the Maine Supreme Judicial Court held that injunctive relief under § 1983 is not categorically precluded by Maine’s separation-of-powers clause and that restoration of good time for nondisciplinary segregation must be a § 1983 remedy, not a Rule 80C remedy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Maine’s separation-of-powers doctrine precludes a court from issuing injunctive relief against the Dept. of Corrections under § 1983	Burr: courts may enjoin constitutional violations by the Department; Bates does not bar § 1983 injunctive relief	Dept.: courts should not intrude on agency policymaking; no ongoing constitutional violation here; § 1983 remedies not guaranteed	The separation-of-powers clause does not categorically bar injunctive relief under § 1983; courts may enjoin specific unconstitutional practices (limited and narrowly tailored)
Whether restoration of good-time credit for time spent in nondisciplinary segregation could be granted via Rule 80C and whether Burr prevailed on his § 1983 claim (fee entitlement)	Burr: restoration of the full 22 months shows he prevailed on § 1983; Rule 80C challenged only disciplinary decision (20 days)	Dept.: restoration was Rule 80C relief; no § 1983 victory, so no § 1988 fees	Restoration of good time for nondisciplinary segregation could not be granted by Rule 80C (it exceeds that forum); it must be treated as a § 1983 remedy. Court must enter judgment for Burr on § 1983, restore good time for nondisciplinary period, and consider § 1988 fees

Bates v. Department of Behavioral & Developmental Services, 863 A.2d 890 (Me. 2004) (rejected receiver remedy; discussed limits on judicial intrusion and availability of injunctive relief)
Department of Corrections v. Superior Court, 622 A.2d 1131 (Me. 1993) (recognized limits on courts directing prison administration but noted § 1983 actions may permit injunctions)
Raynes v. Department of Corrections, 5 A.3d 1038 (Me. 2010) (prison regulation valid if reasonably related to legitimate penological interests)
Turner v. Safley, 482 U.S. 78 (U.S. 1987) (prison restrictions tested for reasonable relation to legitimate penological interests)
Rogers v. Scurr, 676 F.2d 1211 (8th Cir. 1982) (federal courts should avoid prison-management injunctions absent concrete constitutional violation)
Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health & Human Resources, 532 U.S. 598 (U.S. 2001) ("prevailing party" for fee awards requires judicially cognizable change in legal relationship)