Fiandaca v. Cunningham
United States Court of Appeals for the First Circuit
827 F.2d 825 (1987)
New Hampshire Legal Assistance (NHLA) represented Mary Ann Fiandaca and 22 other female New Hampshire prison inmates (collectively, plaintiffs) in a class action suit against the prison’s warden, Michael Cunningham (defendant), and other state officials, for the state’s failure to establish a facility with programs and services equivalent to those provided to male inmates. Prior to trial, Cunningham offered to place a facility on the grounds of Laconia State School and Training Center (LSS). Plaintiffs refused. At the time of its representation of the female inmates, NHLA concurrently represented a group of individuals in a class action suit against state officials challenging the poor conditions at LSS. After a bench trial, the district court held for the plaintiffs and ordered the state to construct a permanent facility for female inmates, but prohibited any facility to be located on LSS grounds because of the ongoing litigation that involved NHLA. Cunningham appealed the district court’s order and claimed that NHLA had a clear conflict of interest and should have been disqualified as counsel for the plaintiffs because the interests of the LSS plaintiffs substantially differed from the interests of the female inmates and when offered a facility on LSS grounds, NHLA should have accepted.
Rule of Law
Holding and Reasoning (Coffin, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 97,000 law students since 2011. Some law schools—such as Yale, Vanderbilt, Berkeley, and the University of Illinois—even subscribe directly to Quimbee for all their law students. Read our student testimonials.
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students. Read more about Quimbee.
Here's why 168,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 13,800 briefs, keyed to 187 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.