Drny V Ny State Dept Of Corr

Disability Rights New York (DRNY) sued the New York State Department of Corrections and Community Supervision (DOCCS) for denying access to records of 32 inmates and one deceased individual with disabilities, asserting violations of federal P&A Acts. DOCCS produced many records post-suit, and New York enacted a law requiring state facilities to provide P&A agencies with free record copies upon written request. The district court granted summary judgment to DOCCS, dismissed DRNY's claims, and denied attorney fees, ruling DRNY was not a prevailing party. DRNY appealed, arguing the court's November 2020 reconsideration order and DOCCS's subsequent policy change entitled it to fees, but the Second Circuit affirmed the dismissal, holding the court's clarification lacked enduring judicial relief and DOCCS's actions followed new state law, not the court order.

The court determined that DRNY was not a prevailing party under 42 U.S.C. § 1988(b) because the relief sought was not judicially sanctioned. DOCCS changed its policy to provide records without physical inspection due to a newly enacted New York state law, not because of the district court's reconsideration order. Thus, the voluntary compliance with the state law, rather than a court judgment, did not confer prevailing party status.

The court affirmed the district court's order, determining that Disability Rights New York (DRNY) was not a prevailing party under 42 U.S.C. § 1988(b). The court held that DRNY did not receive enduring judicial relief altering the legal relationship of the parties, as the district court's reconsideration order did not constitute a material change. The dispute was mooted by New York's 2021-2022 legislation requiring state facilities to provide P&A agency records upon written request, and DOCCS's subsequent voluntary compliance lacked the necessary judicial imprimatur under Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health and Human Resources. The Eleventh Amendment and mootness grounds further supported the dismissal of DRNY's remaining claims.

The court held that a plaintiff becomes a 'prevailing party' under 42 U.S.C. § 1988(b) only when a court grants enduring judicial relief that constitutes a material alteration of the legal relationship of the parties, as established in Lackey v. Stinnie (2025) and Buckhannon Board & Care Home, Inc. v. West Virginia Department of Health and Human Resources (2001). This requires judicially sanctioned relief with enduring nature, not merely voluntary compliance by the defendant.