Law School Case Brief
Miller v. French - 530 U.S. 327, 120 S. Ct. 2246 (2000)
Mandamus is an extraordinary remedy that is granted only in the exercise of sound discretion.
In 1975, prison inmates at the Pendleton Correctional Facility brought a class action to remedy alleged violations of the Eighth Amendment regarding conditions of confinement. The district court issued an injunction, which continued to remain in effect. Congress subsequently enacted the Prison Litigation Reform Act of 1995 (PLRA), which set a standard for the entry and termination of prospective relief in civil actions challenging prison conditions. Specifically, 18 U.S.C. § 3626(b)(2) provided that a defendant or intervenor may move to terminate prospective relief under an existing injunction that did not meet that standard; § 3626(b)(3) provided that a court may not terminate such relief if it made certain findings; and § 3626(e)(2) dictated that a motion to terminate such relief "shall operate as a stay" of that relief beginning 30 days after the motion was filed and ending when the court ruled on the motion. In 1997, petitioner prison officials (hereinafter, "State") filed a motion to terminate the remedial order under § 3626(b). Respondent prisoners moved to enjoin the operation of the automatic stay, arguing that § 3626(e)(2) violated due process and separation of powers principles. The district court enjoined the stay, the State appealed, and the United States intervened to defend § 3626(e)(2)'s constitutionality. In affirming, the Seventh Circuit concluded that § 3626(e)(2) precluded courts from exercising their equitable powers to enjoin the stay, but that the statute, so construed, was unconstitutional on separation of powers grounds.
Was the automatic stay provision unconstitutional?
The Court held that the provision did not violate the separation of powers doctrine because it did not suspend or reopen a U.S. Const. art. III court's judgment, but simply established new standards for the enforcement of prospective relief in 18 U.S.C.S. § 3626(b) and encouraged courts to apply that standard promptly. The language of the automatic stay provision also prohibited federal courts from exercising their equitable authority to suspend operation of an automatic stay. The Court reversed the judgment and remanded for further proceedings.
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