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Miller v. French, 530 U.S. 327 (2000)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Miller v. French, 530 U.S. 327 (2000)
Miller v. French No. 99-224 Argued April 18, 2000 Decided June 19, 2000 * 530 U.S. 327
CERTIORARI TO THE UNITED STATES COURT
OF APPEALS FOR THE SEVENTH CIRCUIT
Syllabus
In 1975, prison inmates at the Pendleton Correctional Facility brought a class action, and the District Court issued an injunction, which remains in effect, to remedy violations of the Eighth Amendment regarding conditions of confinement. Congress subsequently enacted the Prison Litigation Reform Act of 1995 (PLRA), which, as relevant here, sets a standard for the entry and termination of prospective relief in civil actions challenging prison conditions. Specifically, 18 U.S.C. § 3626(b)(2) provides that a defendant or intervenor may move to terminate prospective relief under an existing injunction that does not meet that standard; § 3626(b)(3) provides that a court may not terminate such relief if it makes certain findings; and § 3626(e)(2) dictates that a motion to terminate such relief "shall operate as a stay" of that relief beginning 30 days after the motion is filed and ending when the court rules on the motion. In 1997, petitioner prison officials (hereinafter 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) violates due process and separation of powers principles. The District Court enjoined the stay, the State appealed, and the United States intervened to defend § 3626(e)(2)’s constitutionality. In affirming, the Seventh Circuit 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.
Held:
1. Congress clearly intended to make operation of the PLRA’s automatic stay provision mandatory, precluding courts from exercising their equitable power to enjoin the stay. The Government contends that (1) the Court should not interpret a statute as displacing courts’ traditional equitable authority to preserve the status quo pending resolution on the merits absent the clearest command to the contrary, and (2) reading § 3626(e)(2) to remove that equitable power would raise serious separation of powers questions, and therefore should be avoided under the canon of constitutional doubt. But where, as here, Congress has made its intent clear, this Court must give effect to that intent. Sinclair Refining Co. v. Atkinson, 370 U.S. 195, 215. Under § 3626(e)(2), a stay is automatic once a state defendant has filed a § 3626(b) motion, and the command that it "shall operate as a stay during" the specified time period indicates that it is mandatory throughout that period. The statute’s plain meaning would be subverted were § 3626(e)(2) interpreted merely as a burden-shifting mechanism that does not prevent courts from suspending the stay. Viewing the automatic stay provision in the context of § 3626 as a whole confirms the Court’s conclusion. Section 3626(e)(4) provides for an appeal from an order preventing the automatic stay’s operation, not from the denial of a motion to enjoin a stay. This provision’s one-way nature only makes sense if the stay is required to operate during a specific time period, such that any attempt by a district court to circumvent the mandatory stay is immediately reviewable. Mandamus is not a more appropriate remedy because it is granted only in the exercise of sound discretion. Given that curbing the courts’ equitable discretion was a principal objective of the PLRA, it would have been odd for Congress to have left § 3626(e)(2)’s enforcement to that discretion. Section 3626(e)(3) also does not support the Government’s view, for it only permits the stay’s starting point to be delayed for up to 90 days; it does not affect the stay’s operation once it begins. While construing § 3626(e)(2) to remove courts’ equitable discretion raises constitutional questions, the canon of constitutional doubt permits the Court to avoid such questions only where the saving construction is not plainly contrary to Congress’ intent. Pp. 336-341.
2. Section 3626(e) does not violate separation of powers principles. The Constitution prohibits one branch of the Government from encroaching on the central prerogatives of another. Article III gives the Federal Judiciary the power not merely to rule on cases, but to decide them, subject to review only by superior Article III courts. Plaut v. Spendthrift Farm, Inc., 514 U.S. 211, 218-219. Respondents contend that § 3626(e)(2) violates the separation of powers principle by legislatively suspending a final judgment of an Article III court in violation of Plaut and Hayburn’s Case, 2 Dall. 409. Unlike the situation in Hayburn’s Case, § 3626(e)(2) does not involve direct review of a judicial decision by the Legislative or Executive Branch. Nor does it involve the reopening of a final judgment, as was addressed in Plaut.Plaut was careful to distinguish legislation that attempted to reopen the dismissal of a money damages suit from that altering the prospective effect of injunctions entered by Article III courts. Prospective relief under a continuing, executory decree remains subject to alteration due to changes in the underlying law. Cf. Landgraf v. USI Film Products, 511 U.S. 244, 273. This conclusion follows from the Court’s decision in Pennsylvania v. Wheeling & Belmont Bridge Co., 18 How. 421, 432 (Wheeling Bridge II), that prospective relief it issued in Pennsylvania v. Wheeling & Belmont Bridge Co., 13 How. 518 (Wheeling Bridge I), became unenforceable after Congress altered the law underlying the ongoing relief. Applied here, the Wheeling Bridge II principles demonstrate that § 3626(e)(2)’s automatic stay does not unconstitutionally suspend or reopen an Article III court’s judgment. It does not tell judges when, how, or what to do, but reflects the change implemented by § 3626(b), which establishes new standards for prospective relief. As Plaut and Wheeling Bridge II instruct, when Congress changes the law underlying the judgment awarding such relief, that relief is no longer enforceable to the extent it is inconsistent with the new law. Although the remedial injunction here is a final judgment for purposes of appeal, it is not the last word of the judicial department, for it is subject to the court’s continuing supervisory jurisdiction, and therefore may be altered according to subsequent changes in the law. For the same reasons, § 3626(e)(2) does not violate the separation of powers principle articulated in United States v. Klein, 13 Wall. 128, where the Court found unconstitutional a statute purporting to prescribe rules of decision to the Federal Judiciary in cases pending before it. That § 3626(e)(2) does not itself amend the legal standard does not help respondents; when read in the context of § 3626 as a whole, the provision does not prescribe a rule of decision, but imposes the consequences of the court’s application of the new legal standard. Finally, Congress’ imposition of the time limit in § 3626(e)(2) does not offend the structural concerns underlying the separation of powers. Whether that time is so short that it deprives litigants of an opportunity to be heard is a due process question not before this Court. Nor does the Court have occasion to decide here whether there could be a time constraint on judicial action that was so severe that it implicated structural separation of powers concerns. Pp. 341-350.
178 F.3d 437 reversed and remanded.
O’CONNOR, J., delivered the opinion of the Court, in which REHNQUIST, C.J., and SCALIA, KENNEDY, and THOMAS, JJ., joined, and in which SOUTER and GINSBURG, JJ., joined as to Parts I and II. SOUTER, J., filed an opinion concurring in part and dissenting in part, in which GINSBURG, J., joined, post, p. 350. BREYER, J., filed a dissenting opinion, in which STEVENS, J., joined, post, p. 353.
Contents:
Chicago: U.S. Supreme Court, "Syllabus," Miller v. French, 530 U.S. 327 (2000) in 530 U.S. 327 530 U.S. 328–530 U.S. 331. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=9VL2LFDTH6122UC.
MLA: U.S. Supreme Court. "Syllabus." Miller v. French, 530 U.S. 327 (2000), in 530 U.S. 327, pp. 530 U.S. 328–530 U.S. 331. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=9VL2LFDTH6122UC.
Harvard: U.S. Supreme Court, 'Syllabus' in Miller v. French, 530 U.S. 327 (2000). cited in 2000, 530 U.S. 327, pp.530 U.S. 328–530 U.S. 331. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=9VL2LFDTH6122UC.
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