Hodari v. Alaska Dept. of Corrections
Annotate this CaseIn May 2014, the Alaska Department of Corrections found inmate Sababu Hodari guilty of a disciplinary infraction. Hodari appealed the Department’s decision to the superior court, arguing that the Department violated his right to due process by failing to follow prescribed procedure in the disciplinary hearing. While the appeal was pending the Department reversed its decision and removed the disciplinary records from Hodari’s file. The superior court then found that Hodari had effectively prevailed on his appeal, and it allowed him to recover costs and fees from the Department. Hodari moved for an award of $4,800 in attorney’s and paralegal fees. The court awarded Hodari fees and costs but did not specify the amount of the award in its order, so the Department moved for clarification of the fee-award order. In its clarification order the court stated that because Hodari had not shown that the paralegal fees were for legal work “ordinarily performed by an attorney,” he was only entitled to $1,800 in attorney’s fees. Hodari appealed, arguing that the superior court abused its discretion in refusing to award him paralegal fees. The Alaska Supreme Court disagreed, and therefore affirmed the superior court’s fee award.
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