Rhodes v. Stewart - 488 U.S. 1 (1988)
U.S. Supreme Court
Rhodes v. Stewart, 488 U.S. 1 (1988)
Rhodes v. Stewart
Decided October 17, 1988
488 U.S. 1
While in the custody of the Ohio Department of Rehabilitation and Correction, respondent Stewart and one Reese filed a suit in the District Court under 42 U.S.C. § 1983 alleging violations of their First and Fourteenth Amendment rights by prison officials. After entering a judgment for the plaintiffs, the court entered an award of attorney's fees pursuant to 42 U.S.C. § 1988. On appeal, petitioners argued that, because Reese had died and Stewart had been released, neither plaintiff had been in the State's custody on the day that the District Court had entered its underlying judgment. Nonetheless, the Court of Appeals upheld the fees award, concluding that the claim's mootness when the judgment was issued did not undermine Stewart's status as a prevailing party, since he had won a declaratory judgment. It distinguished this Court's holding in Hewitt v. Helms, 482 U. S. 755 -- that a plaintiff must receive some relief on the merits of his claim before he can be said to have prevailed within the meaning of § 1988 -- on the ground that the plaintiff in Hewitt, unlike Stewart, had not won such a judgment.
Held: Stewart was not a prevailing party under the rule set forth in Hewitt v. Helms, supra, and therefore was not entitled to an award of fees pursuant to § 1988. Nothing in Hewitt suggested that the entry of a declaratory judgment in a party's favor automatically renders that party prevailing. A declaratory judgment, like any other judgment, constitutes relief only if it affects the behavior of the defendant towards the plaintiff. There was no such result in this case, since the lawsuit was
not brought as a class action, and since Stewart could not benefit from any changes in prison policies caused by his lawsuit. Certiorari granted; 845 F.2d 327, reversed.