LaChance v. Commissioner of Correction, 475 Mass. 757

Background

LaChance, a Massachusetts prison inmate, was held in near-solitary confinement in an SMU for ~10 months (Jan–Nov 2006) on "awaiting action" status without a hearing; conditions were like DSU confinement but he received no formal hearing.
He filed a § 1983 suit seeking damages, declaratory relief, and attorney's fees; the Superior Court granted partial summary judgment for declaratory relief in 2010, then on interlocutory appeal this court (LaChance I) clarified due process: >90 days in segregated awaiting-action status creates a liberty interest requiring notice, hearing, and written posthearing decision, and established a 90-day bright-line rule.
On remand final declaratory judgment was entered for LaChance (Aug 21, 2013); he sought $56,504.59 in fees and $392.69 costs under 42 U.S.C. § 1988; the judge awarded $56,372 (lodestar) reduced 50% to $28,186 plus costs, total $28,578.69.
Defendants moved for reconsideration, citing Ford v. Bender (1st Cir. 2014), arguing the declaratory judgment was moot because LaChance was no longer in SMU when judgment entered; the judge denied reconsideration and defendants appealed the fee award.
The Supreme Judicial Court reviewed whether LaChance was a "prevailing party" under § 1988 given mootness concerns, and whether the fee award was reasonable; it affirmed the fee award and allowed LaChance to request appellate fees.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether LaChance is a "prevailing party" under 42 U.S.C. § 1988	LaChance argued his declaratory judgment materially benefited him, was enforceable, and was not moot because he remained in DOC custody and had a reasonable expectation of recurring segregation.	Defendants argued the declaratory judgment was moot (he was discharged from SMU before judgment), so no case or controversy existed and he could not be a prevailing party.	Court held LaChance was a prevailing party: case was not moot under the "capable of repetition, yet evading review" doctrine and the judgment directly benefited him and altered legal relationship.
Whether federal mootness doctrine (Art. III) bars fee recovery here	LaChance relied on repetition/evading-review exception and his affidavit showing repeated prior segregations to satisfy personal stake requirement.	Defendants relied on Rhodes and Ford to say mootness defeats fee awards where relief could not benefit the plaintiff.	Court distinguished Rhodes and Ford: LaChance was still in custody with a reasonable expectation of recurrence, so federal mootness did not preclude relief.
Whether declaratory relief (vs. injunction) suffices to confer prevailing-party status	LaChance argued declaratory judgment against public officials is enforceable and creates a judicial imprimatur altering parties' legal relationship.	Defendants contended declaratory relief that is moot or post hoc cannot confer prevailing-party status.	Court agreed declaratory relief can confer prevailing-party status and was sufficient here because it imposed enforceable protections for future detentions.
Whether the fee award was reasonable (amount)	LaChance argued the lodestar was properly calculated and partial reduction was appropriate given partial success; total award was justified.	Defendants argued award was excessive given limited success and counsel spent more time on unsuccessful claims; urged greater reduction.	Court held the judge did not abuse discretion: lodestar calculated, rates adjusted, and 50% reduction for limited success was reasonable under Hensley/Farrar standards.

Key Cases Cited

LaChance v. Commissioner of Correction, 463 Mass. 767 (Mass. 2012) (established due process protections and 90‑day limit for awaiting‑action segregated confinement)
Farrar v. Hobby, 506 U.S. 103 (U.S. 1992) (standards for prevailing party and damages/fee analysis)
Hensley v. Eckerhart, 461 U.S. 424 (U.S. 1983) (lodestar method and adjustment for partial success)
Buckhannon Bd. & Care Home, Inc. v. West Virginia Dep't of Health & Human Resources, 532 U.S. 598 (U.S. 2001) (judicial imprimatur/material alteration required for prevailing‑party status)
Rhodes v. Stewart, 488 U.S. 1 (U.S. 1988) (mootness can preclude fee awards where plaintiffs obtain no benefit)
Ford v. Bender, 768 F.3d 15 (1st Cir. 2014) (held declaratory relief for pretrial detainee moot when detainee no longer in custody; no prevailing‑party status)
Lefemine v. Wideman, 133 S. Ct. 9 (U.S. 2012) (declaratory or injunctive relief can materially alter the parties' legal relationship)
Mendoza v. Licensing Bd. of Fall River, 444 Mass. 188 (Mass. 2005) (Massachusetts application of Farrar factors for prevailing‑party analysis)
Turner v. Rogers, 564 U.S. 431 (U.S. 2011) (capable‑of‑repetition/evading‑review exception to mootness)