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Law School Case Brief

Miller v. French - 530 U.S. 327, 120 S. Ct. 2246 (2000)

Rule:

The Prison Litigation Reform Act of 1995 (PLRA) establishes standards for the entry and termination of prospective relief in civil actions challenging prison conditions. If prospective relief under an existing injunction does not satisfy these standards, a defendant or intervenor is entitled to immediate termination of that relief. 18 U.S.C.S. § 3626(b)(2). And under the PLRA's automatic stay provision, a motion to terminate prospective relief shall operate as a stay of that relief during the period beginning 30 days after the filing of the motion, extendable to up to 90 days for good cause, and ending when the court rules on the motion. 18 U.S.C.S. § 3626(e)(2) & (3).

Facts:

In 1975, prison inmates at the Pendleton Correctional Facility brought a class action in federal court to remedy alleged violations of the Eighth Amendment regarding conditions of confinement. The district court issued an injunction, which was granted and remained in effect. Congress subsequently enacted the Prison Litigation Reform Act of 1995 (PLRA), which, as relevant here, set a standard for the entry and termination of prospective relief in civil actions challenging prison conditions. Specifically, 18 U.S.C.S. § 3626(b)(2) provided that a defendant or intervenor could move to terminate prospective relief under an existing injunction that did not meet that standard; § 3626(b)(3) provided that a court could 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 ("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 the separation of powers principles. The district court enjoined the stay and the State appealed. The United States also intervened to defend § 3626(e)(2)'s constitutionality. In affirming, the Seventh Circuit Court of Appeals 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.

Issue:

Was the PLRA's automatic stay provision unconstitutional?

Answer:

No

Conclusion:

Judgment reversed and remanded. The United States Supreme Court held that the language of the automatic stay provision, 18 U.S.C.S. § 3626(e)(2), prohibited federal courts from exercising their equitable authority to suspend operation of automatic stay because the statute's language unambiguously provided for a mandatory stay and any construction that preserved courts' equitable discretion to enjoin the automatic stay effectively converted that mandatory stay into a discretionary one. The provision did not violate separation of powers doctrine because it did not suspend or reopen a U.S. Const. art. III court's judgment, as it simply established new standards for enforcement of prospective relief and encouraged courts to apply standard promptly.

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