Bruce v. Samuels

PETITIONER: Antoine Bruce
RESPONDENT: Charles E. Samuels, Jr., et al.
LOCATION: Federal Correctional Institution Talladega

DOCKET NO.: 14-844
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the District of Columbia Circuit

CITATION: 577 US (2016)
GRANTED: Jun 15, 2015
ARGUED: Nov 04, 2015
DECIDED: Jan 12, 2016

ADVOCATES:
Anthony F. Shelley - for the petitioner
Nicole A. Saharsky - Assistant to the Solicitor General, for the respondents

Facts of the case

Several prisoners housed in the Special Management Unit (SMU) of the Federal Correctional Institution in Talladega, which is for gang-affiliated and other disruptive inmates, sued Bureau of Prisons (BOP) officials and claimed that SMUs violated the Eighth Amendment. Because SMUs housed gang-affiliated prisoners, the petitioners argued that the SMUs were unconstitutionally violent and dangerous because the BOP officials did not separate members of rival gangs. The prisoners moved to proceed in forma pauperis, which would allow them to waive filing fees. The parties then engaged in extensive back-and-forth filings regarding the collection of filing fees and the ability of other prisoners to join in the case. The U.S. Court of Appeals for the District of Columbia Circuit held that the Prison Litigation Reform Act prevented the prisoners from completely waiving filing fees, and that they instead must pay a percentage of their monthly income to cover filing fees.

Question

When a prisoner has more than one case or appeal pending in federal courts, does the Prison Litigation Reform Act cap the monthly payment to cover filing fees at 20% of the prisoner’s monthly income?

Media for Bruce v. Samuels

Audio Transcription for Oral Argument - November 04, 2015 in Bruce v. Samuels

Audio Transcription for Opinion Announcement - January 12, 2016 in Bruce v. Samuels

John G. Roberts, Jr.:

In case number 14-844, Bruce versus Samuels, Justice Ginsburg has the opinion of the Court.

Ruth Bader Ginsburg:

The Prison Litigation Reform Act of 1995 installs several measures to reduce frivolous lawsuits brought in federal courts by prisoners.

Among those measures, the statute requires even prisoners who qualify to proceed in forma pauperis to pay filing fees for the suits they launch.

The Act calls for a payment of an initial partial filing fee.

Thereafter, to complete payment of the fee, prisoners must make monthly installment payment of 20% of the income credited to the prisoners’ account in the proceeding month.

It is undisputed that the initial partial filing fee is assessed on a per case basis.

In other words, each time the prisoner files an action, he or she must pay the initial partial fee no matter how many other filing fees the prisoner has incurred.

In contest here, is the calculation of subsequent monthly installment payments for prisoners with more than one outstanding fee obligation.

While these installment payments, like the initial payment, also assessed on a per case basis so that a prisoner would simultaneously contribute toward each outstanding fee, 20% of the preceding month's income or are such payments assessed on a per prisoner basis which would never require a prisoner to pay more than 20% if his preceding month's income and would permit multiple obligations to line up and be discharged sequentially.

Petitioner Antoine Bruce is a federal inmate and a frequent litigant.

In the instant case, he challenges his placement in a special management unit at the Federal Correctional Institution in which he is incarcerated.

He previously incurred filing fee obligations in other cases and maintains that the monthly installment payments for this case are not due until those prior obligations are completely satisfied.

The Court of Appeals for the District of Columbia Circuit whose decision is before us for a review, rejected Bruce's argument aligning itself with the Courts of Appeals that have adopted the “per case approach.”

Other circuits have adopted the “per prisoner approach” and we took this case to resolve the conflict.

We conclude that the statute's text and context fall for the per case approach and we therefore affirm the judgment of the DC Circuit.

Nothing in the statutes designed supports treating of prisoners’ second or third action unlike his first.

Justice here caused for assessment of the initial partial payment of a per case basis so the very next provision demands monthly installment payments of 20% of the proceeding months income simultaneously for each action pursued.

A safety valve provision thought against closing the Court's door to an impoverished prisoner, it means in no event shall a prisoner be prohibited from bringing a civil action or an appeal for the reason that the prisoner has no assets.

The Courts decision is unanimous.