SUMMARY ORDER

This case comes before us following the magistrate judge’s denial of Plaintiff-Appellant Fortunato Garcia’s motion for attorney’s fees pursuant to 42 U.S.C. § 1988. We assume the parties’ familiarity with the underlying facts and the procedural history of the case. On appeal, Garcia argues that he is entitled to attorney’s fees as the “prevailing party” because, although he received no judicially sanctioned relief, his 42 U.S.C. § 1983 action resulted in “important statewide civil rights reform” in Connecticut.

We review the denial of section 1988 fee awards for abuse of discretion. Raishevich v. Foster, 247 F.3d 337, 343 (2d Cir. 2001). “Where, as here, an appellant contends that the district court committed an error of law in ruling on an award of *22 attorney’s fees, we review that ruling de novo.” Roberson v. Giuliani, 346 F.3d 75, 78 (2d Cir. 2003) (citing Baker v. Health Mgmt. Sys., Inc,, 264 F.3d 144, 149 (2d Cir. 2001)).

A “prevailing party” in a section 1983 action may receive “reasonable attorney’s fees.” 42 U.S.C. § 1988(b). A “prevailing party” is “one who has favorably effected a ‘material alteration of the legal relationship of the parties’ by court order.” Garcia v. Yonkers Sch. Dist., 561 F.3d 97, 102 (2d Cir. 2009) (quoting Buckhannon Bd. & Care Home, Inc. v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598, 604, 121 S.Ct. 1835, 149 L.Ed.2d 855 (2001)); see also Tex. State Teachers Ass’n v. Garland Indep. Sch. Dist., 489 U.S. 782, 792, 109 S.Ct. 1486, 103 L.Ed.2d 866 (1989) (“[R]e-spect for ordinary language requires that a plaintiff receive at least some relief on the merits of his claim before he can be said to prevail.”); Hewitt v. Helms, 482 U.S. 755, 760, 107 S.Ct. 2672, 96 L.Ed.2d 654 (1987) (holding that where a plaintiff received no damages award, injunction or .declaratory judgment, or formal judgment in plaintiffs favor, but the defendant unilaterally altered the policies of which -he complained, the plaintiff could not be said to be a prevailing party).

Garcia’s first amended complaint alleged, inter alia, that: he was not arraigned at the Connecticut Superior Court in Bantam, CT; a not guilty plea was entered on his behalf without his presence or the presence of counsel; and court records falsely indicated that he had personally appeared, had entered a guilty plea, and was instructed to appear at a subsequent hearing. A prior panel of this Court affirmed the magistrate judge’s dismissal of Garcia’s first amended complaint on prose-cutorial immunity grounds. Garcia v. Hebert, 352 Fed.Appx. 602, 603 (2d Cir. 2009). The Court’s summary order, however, noted that Garcia’s allegations of prosecutorial misconduct were “disturb[ing]” and “order[ed] the Attorney General of the State of Connecticut ... to provide this Court with a detailed report discussing what steps have been taken to address the practice of the State’s Attorney at the Connecticut Superior Court in Bantam, CT, and what steps are being taken to ensure that they will not continue in the future.” The Connecticut Attorney General’s Office responded “that the previous practice in Bantam of entering not guilty pleas in some instances without the presence of the defendant ceased at least eighteen months ago, and that the cessation of the practice was not related to this or any other litigation.”

Garcia’s argument that he is a prevailing party because his lawsuit caused the Connecticut Superior Court in Bantam to cease its practice of entering guilty pleas without the presence of the defendant essentially asks us to adopt the “catalyst theory” whereby a party “prevails” if its intended result is achieved. See Hewitt, 482 U.S. at 763, 107 S.Ct. 2672. We need not resolve the potential factual discrepancies between the timing of Garcia’s case in the district court and the discontinuance of the offending practice in the Bantam Court because the Supreme Court has expressly rejected the notion embodied in the catalyst theory. See Buckhannon, 532 U.S. at 605,121 S.Ct. 1835 (rejecting “the ‘catalyst theory 1 ” because it “allows an award where there is no judicially sanctioned change in the relationship of the parties [and] ... [t]his is not the type of legal merit that our prior decisions, based upon plain language and congressional intent, have found necessary”); accord Roberson, 346 F.3d at 79 (noting that “after Buck-hannon, a plaintiff must not only achieve some ‘material alteration of the legal relationship of the parties,’ but that change must also be judicially sanctioned”). For *23 this reason, Garcia is not entitled to a section 1988 fee award.

We have considered all of Garcia’s remaining arguments and find them to be without merit. Accordingly, we AFFIRM the judgment of the district court.