Longval v. Superior Court Department of the Trial Court

752 N.E.2d 674, 434 Mass. 718, 2001 Mass. LEXIS 408
CourtMassachusetts Supreme Judicial Court
DecidedAugust 8, 2001
StatusPublished
Cited by18 cases

This text of 752 N.E.2d 674 (Longval v. Superior Court Department of the Trial Court) is published on Counsel Stack Legal Research, covering Massachusetts Supreme Judicial Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Longval v. Superior Court Department of the Trial Court, 752 N.E.2d 674, 434 Mass. 718, 2001 Mass. LEXIS 408 (Mass. 2001).

Opinion

Ireland, J.

This is an appeal from a single justice’s decision denying the plaintiff’s request for declaratory and injunctive relief regarding statutory provisions requiring inmates to pay court filing fees in civil cases. See G. L. c. 261, §§ 27A, 29. The plaintiff, Norman L. Longval, claims that these enactments, among others, unconstitutionally burden both his right to access the courts and his right to equal protection because they treat inmates in a “different and more onerous” manner than other citizens. Following the lead of the Federal courts that have assessed similar arguments, we affirm the single justice’s denial of relief.

1. Development of Law Governing Prisoner Litigation.

In November, 1999, the Legislature enacted a series of statutes designed partially to stem “frivolous” civil litigation by [719]*719prisoners. In particular, the Legislature created G. L. c. 127, §§ 38E-38H, inserted by St. 1999, c. 127, § 133 (establishing grievance procedure for inmate complaints); amended G. L. c. 127, § 129D, through St. 1999, c. 127, § 134 (allowing for reduction in “[g]ood conduct credit” where prisoner files frivolous and bad faith claim “in order to abuse the judicial process”); amended G. L. c. 231, § 6F, through St. 1999, c. 127, § 179 (creating procedural framework to determine whether inmate’s claim is frivolous and, if so, whether sanction is appropriate); and amended G. L. c. 261, § 27A, through St. 1999, c. 127, §§ 180, 181 (setting forth filing fee payment plan for “[ijndigent” inmates). The challenged provisions are modeled after, but are more expansive than, the Federal Prisoner Litigation Reform Act of 1995 (PLRA), an act that Congress passed “with the principal purpose of deterring frivolous prisoner litigation by instituting economic costs for prisoners wishing to file civil claims.”1 Murray v. Dosal, 150 F.3d 814, 816 (8th Cir. 1998), cert. denied, 526 U.S. 1070 (1999), quoting Lyon v. Krol, 127 F.3d 763, 764 (8th Cir. 1997). See Hampton v. Hobbs, 106 F.3d 1281, 1286 (6th Cir. 1997). “The PLRA ‘refashioned the procedures prisoners must observe when seeking to proceed [in forma pauperis] in civil actions.’ ” Murray v. Dosal, supra, quoting Mitchell v. Farcass, 112 F.3d 1483, 1487 (11th Cir. 1997). Specifically, the PLRA (1) authorized Federal courts to dismiss frivolous civil actions commenced by prisoners; (2) empowered courts to impose partial filing fees on prisoners able to pay; (3) limited the amount of attorney’s fees that prisoners can collect pursuant to 42 U.S.C. § 1988 (1994); (4) permitted defendants named in actions filed by prisoners to waive the right to reply to civil complaints without admitting any of the allegations set forth within; and (5) required prisoners to exhaust administrative remedies before seeking judicial relief. 28 U.S.C. [720]*720§ 1915 (1994 & Supp. V 1999). 42 U.S.C. § 1997e (1994 & Supp. V 1999).2

2. Statement of Facts.

On March 27, 2000, the plaintiff moved to waive filing fees and to docket certain appeals in an unrelated case. Absent the necessary financial information, the Appeals Court could not take action on either request and promptly responded, “G. L. c. 261, [§] 29, requires that any inmate seeking to docket an appeal must file a completed affidavit of indigency in support of a motion to waive fees. ... In addition to the completed affidavit form you are also required to submit a current statement of the past six months of your inmate canteen and savings accounts verified by the institution’s treasurer.”3 After encountering difficulty obtaining the requested information, the plaintiff [721]*721filed an action in the Superior Court challenging the constitutionality of G. L. c. 261, § 29, on the ground that it treats inmates differently and more onerously than the population at large. After a single justice denied the plaintiff’s subsequent petition without a hearing, he appealed to the full court.4 See Rushworth v. Registrar of Motor Vehicles, 413 Mass. 265, 268 n.4 (1992) (where government acts under allegedly unconstitutional statute, “it is appropriate for the courts, as soon as reasonably possible, to resolve challenges to the validity of the statute”).

3. Indigency Determination and Filing Fees.

The plaintiff claims that the amendments to G. L. c. 261, §§ 27A and 29, that require him, as an inmate, to submit documentation establishing indigence and to pay court filing fees, violate his right to (1) access the courts and (2) equal protection under the laws. From the outset, we note that the plaintiff does not suggest that the Massachusetts constitutional provisions afford him any greater rights or protections than the comparable Federal constitutional provisions. “Like the Supreme Court of the United States, this court has upheld statutory schemes that impose additional burdens on a particular class of litigants only if such schemes are rationally related to a legitimate legislative purpose.” Murphy v. Commissioner of the Dep’t of Indus. Accs., 415 Mass. 218, 229 (1993). Mindful of the “heavy burden of overcoming the presumption of constitutionality,” we consider whether a “rational basis to a legitimate State interest” underlies the challenged laws. Id. at 232, 233.

Although neither this court nor the Appeals Court has considered the constitutionality of these provisions enacted by St. 1999, c. 127, Federal courts have consistently upheld comparable components of the PLRA on the grounds that they do not violate an inmate’s right to access the courts. See Murray v. Dosal, supra at 817-818 (imposing filing fees on indigent prisoner did not unconstitutionally burden prisoner’s access to courts); Tucker v. Branker, 142 F.3d 1294, 1297 (D.C. Cir. [722]*7221998) (joining “five other circuits in concluding that” PLRA filing fee provisions do not deny prisoners effective access to courts); Roller v. Gunn, 107 F.3d 227, 231-232 (4th Cir.), cert. denied, 522 U.S. 874 (1997) (provisions merely require prisoners to make same economic decisions about filing lawsuits as others).5

Many of the same Federal courts similarly have rejected equal protection challenges to the fee provisions of the PLRA because (1) neither prisoners nor indigents constitute a suspect class; (2) the provisions of the PLRA do not implicate fundamental rights thereby necessitating strict scrutiny; or (3) the provisions of the. PLRA are rationally related to the legitimate governmental interest of deterring frivolous prisoner suits. See Murray v. Dosal, supra at 818; Tucker v. Branker, supra at 1300; Roller v. Gunn, supra at 233-234;

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Bluebook (online)
752 N.E.2d 674, 434 Mass. 718, 2001 Mass. LEXIS 408, Counsel Stack Legal Research, https://law.counselstack.com/opinion/longval-v-superior-court-department-of-the-trial-court-mass-2001.