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.
Pursuant to the Prison Litigation Reform Act (PLRA), petitioner prison superintendent sought to terminate the prospective relief governing the conditions of confinement at its correctional facility. The prisoners filed a motion to enjoin the PLRA's automatic stay provision on the ground that the provision unconstitutional under U.S. Const. art. III. The lower court agreed with the contention of the prisoners and granted the motion to enjoin the PLRA's automatic stay provision, finding it unconstitutional. The decision was appealed.
Was the PLRA's automatic stay provision violative of U.S. Const. art. III?
The appellate court determined that 18 U.S.C.S. § 3626(e)(2) prohibited federal courts from exercising their equitable authority to suspend operation of the 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 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.