Miller v. French

530 U.S. 327, 120 S. Ct. 2246, 147 L. Ed. 2d 326, 2000 U.S. LEXIS 4296
Supreme Court of the United States·Decided June 19, 2000·No. 99-224·Published·Cited by 581 cases

Opinions

[331]*331Justice O’Connor

delivered the opinion of the Court.

The Prison Litigation Reform Act of 1995 (PLRA) establishes standards for the entry and termination of prospective relief in civil actions challenging prison conditions. §§801-810, 110 Stat. 1321-66 to 1321-77. 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. § 3626(b)(2) (1994 ed., Supp. IV). 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. §§ 3626(e)(2), (3). The superintendent of Indiana’s Pendleton Correctional Facility, which is currently operating under an ongoing injunction to remedy violations of the Eighth Amendment regarding conditions of confinement, filed a motion to terminate prospective relief under the PLRA. Respondent prisoners moved to enjoin the operation of the automatic stay provision of § 3626(e)(2), arguing that it is unconstitutional. The District Court enjoined the stay, and the Court of Appeals for the Seventh Circuit affirmed. We must decide whether a district court may enjoin the operation of the PLRA’s automatic stay provision and, if not, whether that provision violates separation of powers principles.

I

A

This litigation began in 1975, when four inmates at what is now the Pendleton Correctional Facility brought a class [332]*332action under Rev. Stat. § 1979, 42 U. S. C. § 1983, on behalf of all persons who were, or would be, confined at the facility against the predecessors in office of petitioners (hereinafter State). 1 Record, Doc. No. 1, p. 2. After a trial, the District Court found that living conditions at the prison violated both state and federal law, including the Eighth Amendment’s prohibition against eruel and unusual punishment, and the court issued an injunction to correct those violations. French v. Owens, 588 F. Supp. 910 (SD Ind. 1982), aff’d in part, vacated and remanded in part, 777 F. 2d 1250 (CA7 1985). While the State’s appeal was pending, this Court decided Pennhurst State School and Hospital v. Halderman, 465 U. S. 89 (1984), which held that the Eleventh Amendment deprives federal courts of jurisdiction over claims for injunctive relief against state officials based on state law. Accordingly, the Court of Appeals for the Seventh Circuit remanded the action to the District Court for reconsideration. 777 F. 2d, at 1251. On remand, the District Court concluded that most of the state law violations also ran afoul of the Eighth Amendment, and it issued an amended remedial order to address those constitutional violations. The order also accounted for improvements in living conditions at the Pendleton facility that had occurred in the interim. Ibid.

The Court of Appeals affirmed the amended remedial order as to those aspects governing overcrowding and double celling, the use of mechanical restraints, staffing, and the quality of food and medical services, but it vacated those portions pertaining to exercise and recreation, protective custody, and fire and occupational safety standards. Id., at 1258. This ongoing injunctive relief has remained in effect ever since, with the last modification occurring in October 1988, when the parties resolved by joint stipulation the remaining issues related to fire and occupational safety standards. 1 Record, Doc. No. 14.

[333]*333B

In 1996, Congress enacted the PLRA. As relevant here, the PLRA establishes standards for the entry and termination of prospective relief in civil actions challenging conditions at prison facilities. Specifically, a court “shall not grant or approve any prospective relief unless the court finds that such relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.” 18 U. S. C. § 8626(a)(1)(A) (1994 ed., Supp. IV). The same criteria apply to existing injunctions, and a defendant or intervenor may move to terminate prospective relief that does not meet this standard. See § 3626(b)(2). In particular, § 3626(b)(2) provides:

“In any civil action with respect to prison conditions, a defendant or intervener shall be entitled to the immediate termination of any prospective relief if the relief was approved or granted in the absence of a finding by the court that the relief is narrowly drawn, extends no further than necessary to correct the violation of the Federal right, and is the least intrusive means necessary to correct the violation of the Federal right.”

A court may not terminate prospective relief, however, if it “makes written findings based on the record that prospective relief remains necessary to correct a current and ongoing violation of the Federal right, extends no further than necessary to correct the violation of the Federal right, and that the prospective relief is narrowly drawn and the least intrusive means necessary to correct the violation.” § 3626(b)(3). The PLRA also requires courts to rule “promptly” on motions to terminate prospective relief, with mandamus available to remedy a court’s failure to do so. § 8626(e)(1).

Finally, the provision at issue here, § 3626(e)(2), dictates that, in certain circumstances, prospective relief shall be [334]*334stayed pending resolution of a motion to terminaba Specifically, subsection (e)(2), entitled “Automatic Stay,” states:

“Any motion to modify or terminate prospective relief made under subsection (b) shall operate as a stay during the period—
“(A)(i) beginning on the 30th day after such motion is filed, in the ease of a motion made under paragraph (1) or (2) of subsection (b);...
“(ii) ... and
“(B) ending on the date the court enters a final order ruling on the motion.”

As one of several 1997 amendments to the PLRA, Congress permitted courts to postpone the entry of the automatic stay for not more than 60 days for “good cause,” which cannot include general congestion of the court’s docket. § 123, 111 Stat. 2470, codified at 18 U.S. C. §3626(e)(3)

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Miller v. French, 530 U.S. 327, 120 S. Ct. 2246, 147 L. Ed. 2d 326, 2000 U.S. LEXIS 4296 (2000).

530 U.S. 327 (Miller v. French) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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