Martin v. Hadix

In 1980, male prisoners at the State Prison of Southern Michigan (prisoners) (plaintiffs) sued the State Prison of Southern Michigan, Central Complex (prison) (defendant) in federal district court, alleging that the conditions of confinement violated their civil rights. The court found for the prisoners and issued a remedial decree. The prisoners’ attorneys engaged in ongoing monitoring of the prison’s compliance with the decree. In 1985, the district court authorized an award of attorney’s fees for this work. On April 26, 1996, the Prison Litigation Reform Act (PLRA) became effective. Section 803(d)(3) of PLRA imposed a limit on awards of attorney’s fees incurred in the litigation of prisoner lawsuits. Prior to the enactment of § 803(d)(3), the prisoners’ attorney’s fees had been capped at $150 per hour. The formula contained in § 803(d)(3) limited attorney’s fees to $112.50 per hour. The prisoners’ attorneys submitted a fee request to the district court for monitoring performed between January 1, 1996, and June 30, 1996. The district court applied the new, reduced fee limit to monitoring performed after the PLRA effective date but not to monitoring performed before the effective date. The prison appealed. The United States Court of Appeals for the Sixth Circuit affirmed the district court. The United States Supreme Court granted certiorari.