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Montana Court Awards PLRA-Capped Attorney Fees Under Catalyst Theory
Loaded on June 15, 2001
published in Prison Legal News
June, 2001, page 23
by Matthew T. Clarke
Filed under:
Conditions of Confinement,
Totality of Conditions,
Attorney Fee Awards,
Attorney Fees (PLRA),
Settlements,
Costs,
Consent Decrees.
Location:
Montana.
A federal district court in Montana has awarded attorney fees to prisoners in a Montana jail, even though the case was settled outofcourt, because the suit was the catalyst of change similar to the relief requested in the suit.
Harry Lozeau and other prisoners at the …
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More from this issue:
- Women Behind Bars, by Silja JA Talvi
- From the Editor, by Paul Wright
- Strikes Sweep Bolivian Prisons as Promise of Freedom Fades, by Julia Lutsky
- Custodial Rape of Female Prisoners Widespread in U.S., by Roger Smith
- Wrongfully Convicted Ohio Man Receives $250,000 Award
- Federal Court Partially Terminates New York Jail Consent Decree Relief
- Texas Prisoners Have Thirty Days to Sue Following Resolution of Grievance
- ADA Settlement at Washington Special Commitment Center, by Hank Balson
- Prisoners of the Census, by Tracy Huling
- Pro Se Tips and Tactics, by John Midgley
- Leave to Amend Complaint Wrongly Denied
- Failure to Notify Prisoner of Hearing Violates Procedural Rights
- Bid to Regain Family Visits Fails in California, by Willie Wisely
- Supreme Court Restricts ADA, by Roger Smith
- Louisiana Prison Activist Freed
- Arbitrary Denial of Michigan Appeal Bond Enjoined
- Costs Allowed Only by Court Order
- Second Circuit Holds Staged Perp Walks Unconstitutional, Grants Qualified Immunity
- $9.6 Million Awarded for Child Death in Illinois Jail
- No Forfeiture Notice Violates Due Process
- Montana Court Awards PLRA-Capped Attorney Fees Under Catalyst Theory
- Prisoner Defendants Entitled to Notice of Summary Judgment Requirements
- Texas Prisoners Have Liberty Interest in Mandatory Supervision
- Guards Use Shotguns to Control Riot
- Unlawful Imprisonment Nets Ohio Man $25,000
- Texas Prisoners Have Right to Appear at Civil Court Hearings
- Washington Media Royalties Sentencing Condition Reversed
- Prison Doctor Wins $654,471 in Retaliation Suit, by John E Dannenberg
- Minnesota Prison Cited For Asbestos Infractions
- Texas Prisoners May Challenge Discretionary Mandatory Release Procedures
- $3 Million Award Not Excessive in Prisoner Beating Death
- Suspicionless Maine Jail Strip Searches Set for Trial; Settles for $455,000
- PLRA-Based Garnishment Used to Collect Court Costs for Defendant
- Indiana Jail Settles Strip Search Case for $300,000
- News in Brief
- Harsh Hitching Post Treatment States Claim
- Ten Percent Prison Commissary Surcharge in New Jersey Upheld
- Statutory Authority Not Required to Levy Housing Costs
- Continuing California's Prison Interview Ban, by Willie Wisely
More from these topics:
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- Florida DOC Rebuked for Seizing Prisoner’s Excessive Force Settlement to Cover Incarceration Liens, Sept. 1, 2026. Summary Judgment, Settlements, Seizure of Prisoner Funds, Trust Accounts, 42 U.S. Code § 1983, civil action for deprivation of rights.
- Atlanta Jail Begins Turning Away Misdemeanor Arrestees, Sept. 1, 2026. Escapes, Staffing, Security Systems, Consent Decrees.
- $500,000 for Mentally Ill Detainee Beaten by Guard at Ohio Jail, Sept. 1, 2026. Guard Brutality/Beatings, Summary Judgment, Settlements, 42 U.S. Code § 1983, civil action for deprivation of rights, Monell Liability.
- $3 Million Paid by San Diego County for Diabetic Detainee’s Jail Death; NaphCare Settles Separately for Undisclosed Amount, Sept. 1, 2026. Naphcare, Diabetes, Failure to Treat, Settlements, Medical Neglect/Malpractice.
- Michigan DOC Legal Payouts Top $7 Million in FY 2025, Less than One Percent of $2.15 Billion Operating Budget, Sept. 1, 2026. Statistics/Trends, Cost of Prison Systems, Damages, Settlements.
- $11 Million Paid by Boston to Exonerated Prisoner for 37-Year Wrongful Incarceration, Sept. 1, 2026. Settlements, Wrongful Conviction, Wrongful Imprisonment, Monell Liability, Withholding of Exculpatory Evidence.
- Federal Court Upholds Consultants’ Finding that Oklahoma Is Not Honoring Its Consent Decree to Provide Mental Health Treatment, Sept. 1, 2026. Consent Decrees, Failure to Treat (Mental Illness), Pretrial Detention and Detainees, Competency Hearing, Inadequate Health Care Facilities.
- Hawai‘i Pays $600,000 for Prisoner’s Withdrawal Death, Sept. 1, 2026. Medication, Drug/Alcohol Withdrawal, Failure to Treat, Settlements, Medical Neglect/Malpractice.
- $3 Million Settlement Reached with BOP for Attorney’s Fees in Sex Abuse Class-Action from Now-Shuttered California “Rape Club”, Aug. 1, 2026. Staff-Prisoner Assault, Attorney Fee Awards, Settlements, Consent Decrees, Class Actions.

