Hewitt v. Helms, 482 U.S. 755 (1987)

Author: U.S. Supreme Court

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Hewitt v. Helms, 482 U.S. 755 (1987)

Hewitt v. Helms

No. 85-1630

Argued March 4, 1987
Decided June 19, 1987
482 U.S. 755



After more than seven weeks in administrative segregation pending an investigation into his possible involvement in a state prison riot, respondent inmate was found guilty of misconduct by a prison hearing committee and sentenced to six months of disciplinary confinement solely on the basis of an officer’s report of the statements of an undisclosed informant. Respondent filed suit against petitioner prison officials for damages and injunctive relief under 42 U.S.C. § 1983, but was released on parole before any decision was rendered. Subsequently, the Court of Appeals reversed the District Court’s entry of summary judgment against respondent, finding, inter alia, that his misconduct conviction constituted a denial of due process, since it was based solely on hearsay. The District Court was instructed to enter summary judgment for respondent unless petitioners could establish an immunity defense, and was given authority to determine the appropriateness and availability of the relief respondent requested. On remand, respondent pursued only his damages claim. The District Court granted summary judgment for petitioners on the basis of qualified immunity, and the Court of Appeals affirmed. While the appeal was pending, the State Corrections Bureau (Bureau) revised its regulations to include procedures for the use of confidential source information in inmate disciplinary proceedings. The District Court then denied respondent’s claim for attorney’s fees on the ground that he was not a "prevailing party" as required by 42 U.S.C. § 1988, but the Court of Appeals reversed, concluding that its prior holding that his constitutional rights had been violated was "a form of judicial relief." In the alternative, the court directed the District Court to reconsider whether respondent’s suit was a "catalyst" for the amendment of the Bureau’s regulations.

Held: Respondent is not a "prevailing party" eligible for attorney’s fees under § 1988. A plaintiff must receive at least some relief on the merits of his claim before he can be said to "prevail." Respondent obtained neither a damages award, injunction, or declaratory judgment, nor a consent decree, settlement, or other relief without benefit of a formal judgment. Pp. 759-764.

(a) 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." The Court of Appeals’ treatment of its initial constitutional holding as "a form of judicial relief" -- presumably a form of declaratory judgment -- was in error, since the court neither granted nor ordered relief of any kind. Even if respondent’s nonmonetary claims were not rendered moot by his release from prison, and it could be said that those claims were kept alive by his interest in expunging his misconduct conviction from his prison record, his counsel never took the steps necessary to have a declaratory judgment or expungement order properly entered. The argument that the Court of Appeals’ initial holding is a "vindication of rights" that is at least the equivalent of declaratory relief ignores the fact that a judicial decree is not the end of the judicial process, but is rather the means of prompting some action (or cessation of action) by the defendant. Here, respondent obtained nothing from petitioners. Moreover, equating statements of law (even legal holdings en route to a final judgment for the defendant) with declaratory judgments has the practical effect of depriving the defendant of any valid defenses that a court might take into account in deciding whether to enter a declaratory judgment. Furthermore, the same considerations that influence courts to issue declaratory judgments may not enter into the decision whether to include statements of law in opinions. However, if they do, the court’s decision is not appealable in the same manner as its entry of a declaratory judgment. Pp. 759-763.

(b) The alternative argument that a hearing is required to determine whether respondent’s suit prompted the Bureau to amend its regulations also fails. Even if respondent can demonstrate a clear causal link between his lawsuit and the amendment, and can "prevail" by having the State take action that his complaint did not in terms request, he did not obtain redress from that amendment, since he had long since been released from prison at the time it was issued. Pp. 763-764.

780 F.2d 367, reversed.

SCALIA, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and WHITE, POWELL, and O’CONNOR, JJ., joined. MARSHALL, J., filed a dissenting opinion, in which BRENNAN, BLACKMUN, and STEVENS, JJ., joined, post, p. 764.


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Chicago: U.S. Supreme Court, "Syllabus," Hewitt v. Helms, 482 U.S. 755 (1987) in 482 U.S. 755 482 U.S. 756–482 U.S. 757. Original Sources, accessed March 2, 2024, http://www.originalsources.com/Document.aspx?DocID=963R2Y86XX723ZA.

MLA: U.S. Supreme Court. "Syllabus." Hewitt v. Helms, 482 U.S. 755 (1987), in 482 U.S. 755, pp. 482 U.S. 756–482 U.S. 757. Original Sources. 2 Mar. 2024. http://www.originalsources.com/Document.aspx?DocID=963R2Y86XX723ZA.

Harvard: U.S. Supreme Court, 'Syllabus' in Hewitt v. Helms, 482 U.S. 755 (1987). cited in 1987, 482 U.S. 755, pp.482 U.S. 756–482 U.S. 757. Original Sources, retrieved 2 March 2024, from http://www.originalsources.com/Document.aspx?DocID=963R2Y86XX723ZA.