February 21, 2018

Supreme Court Decides Murphy v. Smith

On February 21, 2018, the United States Supreme Court decided Murphy v. Smith, No. 16-1067, holding that when a prisoner receives a judgment under certain civil rights statutes, the district court must apply as much of the prisoner’s judgment as necessary, up to 25 percent, to satisfy any award of attorney’s fees.

When a prisoner wins a civil rights suit and the district court awards fees to the prisoner’s attorney pursuant to 42 U. S. C. §1997e(d)(2), “a portion of the [prisoner’s] judgment (not to exceed 25 percent) shall be applied to satisfy the amount of attorney’s fees awarded against the defendant. If the award of attorney’s fees is not greater than 150 percent of the judgment, the excess shall be paid by the defendant.” 42 U. S. C. §1997e(d)(2).

The plaintiff was a prisoner who was awarded a judgment in a federal civil rights suit against two of his prison guards, including an award of attorney’s fees. Despite the statute’s terms, the district court ordered Mr. Murphy to pay only 10 percent of his judgment toward the fee award, leaving defendants responsible for the remainder. The Seventh Circuit re¬versed, holding that §1997e(d)(2) required the district court to exhaust 25 percent of the prisoner’s judgment before demanding payment from the defendants.

The Supreme Court affirmed. The Court held that the language of the statute in issue suggested that the court (1) must apply judgment funds toward the fee award (2) with the purpose of (3) fully discharging the fee award. And to meet that duty, a district court must apply as much of the judgment as necessary—up to the 25 percent cap—to satisfy the fee award. The Court reasoned that the surrounding statutory structure of § 1997e(d) reinforces this conclusion through new statutory language limiting the district court’s discretion in prisoner civil rights lawsuits.

Justice Gorsuch delivered the opinion of the Court, in which Chief Justice Roberts and Justices Kennedy, Thomas and Alito joined. Justice Sotomayor filed a dissenting opinion in which Justices Ginsburg, Breyer, and Kagan joined.

Download Opinion of the Court.

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