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Miller v. French

United States Supreme Court
530 U.S. 327 (2000)


Facts

In 1975, French and other inmates (prisoners) (plaintiffs) brought a class-action suit against Miller, the Superintendent of the Pendleton Correctional Facility, and other officials (state) (defendants), for cruel and unusual punishment concerning conditions at the prison. The court issued an injunction in order to correct violations and improve living conditions for prisoners, and the injunctive relief remained in effect at the time of this suit. In 1996, Congress enacted the Prisoner Litigation Relief Act (PLRA), 18 U.S.C. § 3626, which set forth new standards governing when a court could enter prospective relief against a prison. If current injunctions were alleged not to meet the new standards, states could move for termination of the injunction, which would trigger an automatic stay of the injunction under § 3626(e)(2) of the PLRA. The state moved to terminate the injunction in 1997, and the prisoners moved to enjoin the automatic stay, arguing it violated separation-of-powers principles and due process rights. The district court granted the prisoners’ motion and enjoined the automatic stay. The Court of Appeals for the Seventh Circuit affirmed and held the automatic stay provision of the PLRA unconstitutional as a violation of the separation of powers. The United States Supreme Court granted certiorari to resolve a conflict among courts of appeal.

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Dissent (Breyer, J.)

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