Frank Haygood v. Evelle J. Younger, Etc., and Harold Cranke and Benjamin Seymour

Harold Cranke and Benjamin Seymour, records officers at Folsom State Prison and the California Department of Corrections, respectively, appeal from the district court’s denial of their motion for judgment notwithstanding the verdict in a section 1983 action. Frank Haygood alleged that Cranke and Seymour violated his due process and Eighth Amendment rights by improperly investigating his legal status while he was incarcerated pursuant to a series of concurrent and consecutive sentences. He contended that their conduct resulted in his unlawful confinement beyond the actual term of those sentences. The jury returned a general verdict of $2,090 in damages. Cranke and Seymour also appeal the award of $45,383 in attorney’s fees. We reverse and remand.

I.

FACTS

The decision of the California Supreme Court, which appears in part in the margin, granting Haygood’s habeas corpus petition provides the background facts leading to his release. See In re Haygood, 14 Cal.3d 802 , 122 Cal.Rptr. 760 , 537 P.2d 880 (1975). 1958 is a good year in which to commence the recital of facts particularly relevant to -this case. Haygood escaped in that year from a prison camp while serving concurrent…