PRISON LITIGATION REFORM ACT

Issues

The Supreme Court will decide whether section 1915(b)(2) of the Prison Litigation Reform Act requires prisoners who file multiple actions in forma pauperis to pay a monthly installment on a “per-prisoner” basis, where prisoners owe no more than 20% of their preceding month’s income regardless of the number of cases for which they owe filing fee; or on a “ per-case ” basis, where a prisoner must pay 20% of her preceding month’s income for each case for which she owes a filing fee. See Brief for Petitioner, Antoine Bruce at 1–2. Federal prisoner Antoine Bruce argues that the monthly payments should be calculated on a per-prisoner basis, while Federal Bureau of Prisons Director Charles E. Samuels, Jr. argues that the payments should be calculated on a per-case basis. See id. at 16; Brief for Respondents, Charles E. Samuels, Jr., et al. at 13. The parties diverge sharply in their interpretations of the text of the statute, congressional intent, the statute’s purposes, and the constitutional-avoidance canon. See Brief for Petitioner at 16, 22, 32, 42, 49; Brief for Respondents at 13, 42, 46. The Court’s ruling will resolve a circuit split between the Second, Third, and Fourth Circuits, which apply a per-prisoner cap, and the Fifth, Seventh, Eighth, and Tenth Circuits, which apply a per-case cap. Additionally, the case will impact prisoners’ access to the courts and administrative costs associated with prisoner cases. See Brief for Petitioner at 11.

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The Supreme Court will decide whether, under the three-strikes provision of the Prison Litigation Reform Act (“§ 1915”), a district court’s dismissal of a suit counts as a strike while it is still pending on appeal or before the time for seeking appellate review has passed. Andre Lee Coleman, a prisoner in Michigan, was barred under § 1915 from proceeding on a fourth action in forma pauperis while the decision from a previous action was on appeal in district court. Coleman argues that the district court improperly dismissed his action when it counted the pending appeal of his action as a third strike in accordance with § 1915(g). However, Tollefson counters that the strike should be in effect after the district court dismissal due to the PLRA’s text and Congress’s desire to ban meritless claims. This decision has the potential to affect how the statute is interpreted in the lower courts and the caseload volume of court dockets.

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The Supreme Court will decide whether a reasonable belief exception applies to the Prison Litigation Reform Act (“PLRA”), 42 U.S.C. 1997(e). The PLRA requires that “[n]o action shall be brought with respect to prison conditions . . . until such administrative remedies as are available are exhausted.” Respondent Shaidon Blake, an inmate serving a life sentence in Maryland state prison, sued two prison officers, Michael Ross and James Madigan (collectively, “Ross”), in federal court for injuries sustained during an altercation. Blake did not first pursue relief through Maryland’s formal Administrative Remedy Process (“ARP”), but instead filed a complaint with the prison’s Internal Investigations Unit (“IIU”). Ross argues that because the PLRA’s mandate is strict, Blake lacks standing under the law to sue. He contends that both Congressional intent and the express text of the statute clearly foreclose the judiciary’s ability to import any “traditional” exceptions to administrative exhaustion into the PLRA. But Blake asserts that the IIU investigation precluded the option of pursuing any other administrative remedy. Even if it had not, he contends that the ARP system is far too complex to qualify as “available” under federal law. Consequently, Blake holds that the Court need not reach the issue presented because he properly exhausted all available remedies. The Court’s decision could affect prison management and prisoners’ rights.

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Plata v. Schwarzenegger and Coleman v. Schwarzenegger were separate class actions concerning healthcare conditions in California state prisons. Although the cases were decided separately, they resulted in similar outcomes: the district court in each case determined that the lack of adequate physical or mental care violated the prisoners’ Eighth Amendment rights, leading to years of court orders designed to remedy the violations. After California Governor Arnold Schwarzenegger declared a state of emergency due to prison overcrowding in 2006, the Plata and Coleman plaintiffs argued that the only means of remedying the continued constitutional violations was the release of significant numbers of inmates from state prisons. Subsequently, a three-judge district court convened under the Prison Litigation Reform Act (“PLRA”) issued a prisoner release order. Governor Schwarzenegger and other state officials (“Schwarzenegger”) appealed the decision to the Supreme Court. They contend that the three-judge district court improperly applied the PLRA because California had not had sufficient time to implement the latest court order. Schwarzenegger also contends that the district court failed to determine that overcrowding was the primary cause of the violations. In response, the Plata and Coleman plaintiffs, along with the California Correctional Police Officers’ Association, argue that the PLRA was properly applied because the state was given a reasonable amount of time to comply with previous court orders and the prisoner release order remedied the primary cause of the violations. The Supreme Court’s decision will determine when courts may remedy constitutional violations through a prisoner release order under the PLRA, and could dramatically alter the number of prisoners and the services provided in California prisons.

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