Jones v. Hayman

The opinion of the court was delivered by

FUENTES, J.A.D.

This appeal requires us to consider under what circumstances a plaintiff, who brings an action pursuant to statutes containing fee-shifting provisions, may be deemed a prevailing party under the catalyst theory when the underlying action is dismissed as moot without a final judicial determination on the merits of the case.

Plaintiffs Kathleen Jones, Lakesha Jones, Sylvia Flynn, and Helen Ewell were four inmates initially confined in the Edna Mahan Correctional Facility (EMCF), an all-female penal facility. Following their transfer, along…