Supreme Court of the United States
Martin v. Hadix
June 21, 1999527 U.S. 343
Summary
The Court held that the Prison Litigation Reform Act's attorney-fee cap does not apply to postjudgment monitoring work performed before the Act's effective date, because applying it to completed work would have retroactive effect absent a clear congressional directive. The cap does apply to monitoring work performed after the effective date because attorneys had notice of the reduced rate before undertaking that future work. Justice Ginsburg, joined by Justice Stevens, would have held the cap inapplicable to cases commenced before the Act, while Justice Scalia concurred in the judgment on the ground that the relevant conduct was the performance of legal work.
Holding
- Application of the fee cap to postjudgment monitoring performed before the Act's effective date. The fee cap does not apply to attorney work performed before the Act's effective date.
- Application of the fee cap to postjudgment monitoring performed after the Act's effective date. The fee cap applies to postjudgment monitoring work performed after the Act's effective date, including in cases that were already pending.
Docket 98-262