U.S. District Court: PLRA-Prison Litigation Reform Act, CONSENT DECREE-DETERMINATION.

• Position: Brief Article

Lozeau v. Lake County. Mont., 98 F.Supp.2d 1157 (D.Mont. 2000). Jail inmates filed an action to enforce the provisions of a consent decree that governed prison conditions. After the suit was resolved by a settlement, the inmates sought attorney fees. The district court held that the inmates were entitled to attorney fees even though the case was settled because the inmates' suit was the catalyst for improved compliance. The court ruled that the fees of an out-of-state attorney with special civil...