Supreme Court of the United States
Murphy v. Smith
February 21, 2018583 U.S. 220
Summary
The Supreme Court held that, under 42 U.S.C. §1997e(d)(2), district courts must apply as much of a prevailing prisoner’s judgment as necessary—up to the 25 percent cap—to satisfy the attorney’s fee award. The Court interpreted the mandatory language “shall be applied to satisfy” as creating a nondiscretionary duty to fully discharge the fee award within that limit, and affirmed the Seventh Circuit’s reversal of the district court’s 10 percent allocation.
Holding
- Whether §1997e(d)(2) obligates district courts to apply as much of the judgment as necessary, up to 25 percent, to satisfy the fee award. Yes; district courts must apply as much of the judgment as necessary, without exceeding 25 percent, to satisfy the attorney’s fee award
- Whether the statutory language permits any discretion in the amount applied, short of the 25 percent maximum. No; the statute does not grant discretion to apply a lesser portion once the fee award can be satisfied within the 25 percent limit
Docket 16-1067
Cited authorities
- 42 U. S. C. 2
- 42 U.S.C. §1988
- 90 Stat. 2641
- 42 U.S.C. §1983
- 116 Harv. L. Rev. 1555
- 42 U.S.C. §1988