Miller v. French

PETITIONER: Miller
RESPONDENT: French
LOCATION: Florida State University

DOCKET NO.: 99-224
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Seventh Circuit

CITATION: 530 US 327 (2000)
ARGUED: Apr 18, 2000
DECIDED: Jun 19, 2000

ADVOCATES:
Barbara D. Underwood - Argued the cause for the United States, on behalf of the petitioners
Jon Laramore - Argued the cause for petitioners
Kenneth J. Falk - Argued the cause for the respondents

Facts of the case

In 1975, inmates at the Pendleton Correctional Facility filed a class action lawsuit, which ultimately led the District Court to issue an injunction to remedy Eighth Amendment violations regarding conditions of confinement. In 1996, Congress enacted the Prison Litigation Reform Act of 1995 (PLRA), which sets a standard for the entry and termination of prospective relief in civil actions challenging prison conditions. The PLRA provides that a motion to terminate such relief "shall operate as a stay" of that relief beginning 30 days after the motion is filed and ending when the court rules on the motion. In 1997, the State of Indiana filed a motion to terminate the remedial order against the correctional facility. Under the PLRA, the motion stayed the court's original remedial order. The prisoners of Pendleton moved to enjoin the operation of the automatic stay, arguing that the automatic stay provision of the PLRA violated due process and the separation of powers doctrine. The District Court enjoined the stay. In affirming, the Court of Appeals found that the provision precluded courts from exercising their equitable powers to enjoin the stay, but concluded that the statute was unconstitutional on separation of powers grounds.

Question

Does the Prison Litigation Reform Act of 1995's "automatic stay" provision preclude courts from exercising their equitable powers to enjoin such a stay? Does the provision violate the constitutional separation-of-powers doctrine?

Media for Miller v. French

Audio Transcription for Oral Argument - April 18, 2000 in Miller v. French

Audio Transcription for Opinion Announcement - June 19, 2000 in Miller v. French

The opinion of the Court in No. 99-224, Miller against French and a companion case will be announced by Justice O’Conner.

Sandra Day O'Connor:

These cases come to us on writ of certiorari from the Court of Appeals for the Seventh Circuit.

In 1996, Congress enacted the Prison Litigation Reform Act.

All these things have acronyms; this one is called the PLRA, and as relevant here that PLRA establishes standards for the entry and termination of prospective relief in civil actions challenging prison conditions.

Specifically Section 3626(b) provides that prospective relief must be supported by findings and precisely tailored to what is needed to remedy the violation of a federal right.

If prospective relief, under an existing injunction, does not satisfy these standards, the PLRA entitles a defendant or intervenor to immediate termination of the prospective relief.

Under the automatic stay provision of the PLRA, the provision that is at issue in this case, a motion determinate prospective relief shall operate as a stay of that relief during the period beginning 30 days after filing of the motion which is extendable up to 90 days for good cause.

The stay ends when the court rules on the motion for termination.

In 1997, the Superintendent of the Pendleton Correctional Facility, which is currently operating under an ongoing injunction governing the conditions of confinement there, filed a motion to terminate the prospective relief.

The District Court enjoined the automatic stay provision of the PLRA.

The Court of Appeals for the Seventh Circuit affirmed concluding that although the state provision precluded courts from using their equitable powers to enjoin the stay, the statue so construed was unconstitutional on separation of power’s grounds.

In an opinion filed with the Clerk of the Court today, we reverse.

The first question is whether the automatic stay provision precludes federal courts from exercising their traditional equitable powers to enjoin the automatic stay.

We conclude that it does, the text of the statue unambiguously requires that the motion shall operate as a stay during a specific time period.

Any construction of this language that allowed courts to use their equitable discretion to enjoin a stay would be plainly contrary to Congress’ intent because it would convert the mandatory stay into a discretionary one.

Given this construction, we must address whether the stay provision offends separation of powers principles.

In 1995, in a case called Plaut versus Spendthrift Farm, we held that a statue that required federal courts to reopen final judgments entered before the status’s enactment was unconstitutional.

We distinguished in that case, however, those situations in which the legislation altered the prospective effect of previously entered injunctions.

We have held that prospective relief remains subject to alteration due to changes in the underlying law.

Section 3626(b), if the PLRA changes the relevant underlying law by establishing new standards for the enforcement of prospective relief.

By staying prospective relief that is no longer enforceable under the new standards, the stay provision merely reflects the change in the underlying law; it does not suspend or reopen a final judgment.

Consequently, we conclude that the stay provision does not offends separation of powers principle.

Justice Souter has filed an opinion concurring in part and dissenting in part which Justice Ginsburg has joined; Justice Breyer has filed a dissenting opinion joined by Justice Stevens.