Planned v. Ayotte

2008 DNH 155
CourtDistrict Court, D. New Hampshire
DecidedAugust 12, 2008
DocketCivil 03-cv-491-JD
StatusPublished

This text of 2008 DNH 155 (Planned v. Ayotte) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Planned v. Ayotte, 2008 DNH 155 (D.N.H. 2008).

Opinion

Planned v . Ayotte 03-CV-491-JD 08/12/08 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Planned Parenthood of Northern New England, Concord Feminist Health Center, Feminist Health Center of Portsmouth, and Wayne Goldner, M.D. v. Civil N o . 03-cv-491-JD Opinion N o . 2008 DNH 155 Kelly Ayotte, Attorney General

O R D E R

The plaintiffs brought a class action under 42 U.S.C. §

1983, seeking a declaration that New Hampshire’s Parental

Notification Prior to Abortion Act was unconstitutional and an

injunction to bar enforcement of the Act. After the Act was

repealed and the suit was dismissed as moot, the plaintiffs moved

for an award of attorneys’ fees and costs pursuant to 42 U.S.C. §

1988. The State of New Hampshire objects to the motion,

contending that the plaintiffs are not prevailing parties and,

therefore, are not entitled to fees and costs.1

The parties filed an assented-to motion for a briefing

schedule to address the question of an award of attorneys’ fees.

1 Because Peter Heed, who was replaced by Kelly Ayotte, was sued in his official capacity as Attorney General of the State of New Hampshire, the state is treated as the defendant. See Negron-Almeda v . Santiago, 528 F.3d 1 5 , 21 n.2 (1st Cir. 2008). The court granted the motion, which limited the parties’ initial

filings to the issue of whether the plaintiffs are entitled to

fees. If the court concludes that the plaintiffs are entitled to

fees, the parties then will address the amount of fees.

Standard of Review

Section 1988 provides an exception to the rule that

litigants generally pay their own attorneys’ fees. Sole v .

Wyner, 127 S . Ct 2188, 2191 (2007). Under that exception, “the

court, in its discretion, may allow the prevailing party, other

than the United States, a reasonable attorney’s fee as part of

the costs.” “The touchstone of the prevailing party inquiry . .

. is the material alteration of the legal relationship of the

parties in a manner in which Congress sought to promote in the

fee statute.” Id. at 2194 (internal quotation marks omitted).

“A party is a prevailing party when actual relief on the

merits of his claim materially alters the legal relationship

between the parties by modifying the defendant’s behavior in a

way that directly benefits the plaintiff.” Rossello-Gonzalez v .

Acevedo-Vila, 483 F.3d 1 , 5 (1st Cir. 2007). Therefore, a party

who initially achieves a preliminary injunction but later loses

on the merits of the challenge is not a prevailing party for

purposes of § 1988(b). Sole, 127 S . C t . at 2196. On the other

2 hand, parties who receive only nominal damages or partial success

are prevailing parties if they succeeded on any significant issue

and achieved at least some of the benefit that they sought in the

litigation. Farrar v . Hobby, 506 U.S. 103, 109 (1992).

Nevertheless, “to qualify as a prevailing party, a civil rights

plaintiff must obtain at least some relief on the merits of his claim [and] . . . must obtain an enforceable judgment against the

defendant from whom fees are sought . . . or comparable relief

through a consent decree or settlement.” Id. at 111.

Background

The New Hampshire legislature enacted the Parental

Notification Prior to Abortion Act, RSA 132:24 - 132:28, in 2003,

with an effective date of December 3 1 , 2003. “The Act

prohibit[ed] physicians from performing an abortion on a pregnant

minor (or a woman for whom a guardian or conservator has been

appointed) until 48 hours after written notice of the pending

abortion is delivered to her parent or guardian.” Ayotte v .

Planned Parenthood of N . New England, 546 U.S. 3 2 0 , 323 (2006).

Planned Parenthood of Northern New England, Concord Feminist

Health Center, Feminist Health Center of Portsmouth, and Wayne

Goldner, M.D. (“the Plaintiffs”), filed suit on November 1 7 ,

2003, challenging the constitutionality of the Act and seeking

3 injunctive and declaratory relief under § 1983.

The Plaintiffs alleged that the Act was unconstitutional

because it lacked an “exception to its notice and delay

requirements for circumstances in which delay will threaten the

health of the young woman.” Compl. ¶ 2 . The Plaintiffs also

alleged that the death exception, RSA 132:26, I ( a ) , was too narrow and that the confidentiality provision for the judicial

bypass procedure, RSA 132:26, II(b), was inadequate to meet

constitutional requirements. The Plaintiffs sought expedited

review and a preliminary injunction against enforcement of the

Act, beginning on its effective date.

The State objected, arguing that because the Plaintiffs

brought a facial challenge to the Act’s constitutionality the

heightened standard of review used in United States v . Salerno,

481 U.S. 739 (1981), applied to the Plaintiffs’ claims, and that the Act was not unconstitutional. Specifically, the State

contended that the lack of a health exception was not

unconstitutional because other New Hampshire laws permitted

physicians to perform emergency medical care, despite a lack of

consent, without civil liability in certain circumstances.

Alternatively, the State argued that the judicial bypass

provision in the Act adequately protected the health of a

pregnant minor. The State also argued that the death exception

4 and confidentiality provision were constitutionally adequate.

The State further asked that if any parts of the Act were found

to be unconstitutional, those parts should be severed, pursuant

to the Act’s severability clause, from the constitutional

portions.

On November 1 8 , 2003, the court held a telephone conference with counsel to set a briefing schedule and to consider other

procedural matters. The court asked whether the Plaintiffs would

agree to consolidate their motion for a preliminary injunction

with the merits of the case. Later, in the absence of a

response, the court concluded that the Plaintiffs agreed to

consolidation and considered the case on the merits.

To determine whether or not the Act was facially

unconstitutional, the court reviewed the different standards used

to decide that issue and concluded that the Salerno standard did not apply when, as in this case, the challenged legislation

restricted access to an abortion, a constitutionally protected

action. Planned Parenthood of N . New England v . Heed, 296 F.

Supp. 5 9 , 63 (D.N.H. 2003). Instead, the appropriate standard

was whether the challenged law imposed an “undue burden” or a

“substantial obstacle” to a woman’s choice to undergo an

abortion. Id. The court concluded that the Act was

unconstitutional because it lacked a health exception and because

5 the death exception and confidentiality provision were

inadequate. Id. at 66-67. The court also ruled that the

severability clause did not apply because the lack of a health

exception made the Act unconstitutional and no excision of

unconstitutional parts would remedy its deficiencies. Id. at 6 7 .

The court granted the Plaintiffs’ request for a declaratory judgment, as follows: “For the foregoing reasons, the Act, to be

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Salerno
481 U.S. 739 (Supreme Court, 1987)
Farrar v. Hobby
506 U.S. 103 (Supreme Court, 1992)
United States v. Weikert
504 F.3d 1 (First Circuit, 2007)
Leal Santos v. Mukasey
516 F.3d 1 (First Circuit, 2008)
Rosado-Quiñones v. Toledo
528 F.3d 1 (First Circuit, 2008)
Planned Parenthood of Northern New England v. Ayotte
571 F. Supp. 2d 265 (D. New Hampshire, 2008)
Cesarini v. United States
296 F. Supp. 3 (N.D. Ohio, 1969)
Dye v. Hofbauer
546 U.S. 1 (Supreme Court, 2005)
United States v. Vega-Santiago
519 F.3d 1 (First Circuit, 2008)
Evans v. Thompson
524 F.3d 1 (First Circuit, 2008)

Cite This Page — Counsel Stack

Bluebook (online)
2008 DNH 155, Counsel Stack Legal Research, https://law.counselstack.com/opinion/planned-v-ayotte-nhd-2008.