High Court Rules Against Beaten Inmate in Attorney’s Fees Case

(CN) – A divided Supreme Court on Wednesday ruled that a federal statute governing how much prevailing prisoners must pay their lawyers is unambiguous, and that as a result, 25 percent of their judgment must be used to cover attorney’s fees before defendants have to pick up any of the cost.

The case before the court involved Charles Murphy, an inmate in the Vandalia Correctional Center in Illinois, who was assaulted by two corrections officers in July 2011.

Murphy was left with a fractured eye socket and sued the officers on claims that their blows caused his injury and that they failed to provide him with proper medical care afterwards. A jury returned a verdict in Murphy’s favor, awarding him $307,734 in damages.

It also set the attorney’s fees in the case at $108,446, and the judge presiding in the case ruled  Murphy had to use 10 percent of his award, or about $31,000, to pay a portion of the fees and that the defendants guards were liable for the rest.

The corrections officers appealed the judgment, arguing that the Illinois doctrine of sovereign immunity bars the state-law claims and that the Prison Litigation Reform Act requires that 25 percent of the damages awarded be used to pay the attorney fee award.

The Seventh Circuit affirmed the district court’s holding that the state officials or employees are not entitled to sovereign immunity against state-law claims in cases where the officials or employees violated statutory or constitutional law, but it reversed on the attorney fee award.

In doing so, the Seventh Circuit said 42 U.S.C. § 1997e(d) requires that the attorney fee award must first be satisfied from up to 25 percent of the damage award and that the district court does not have discretion to reduce that maximum percentage. Murphy appealed to the U.S. Supreme Court.

In a ruling for the majority that relied heavily on the 2002 edition of the Cambridge Grammar of the English Language, Justice Neil Gorsuch said the specific statutory language of the statute uses the word “shall,” as in “shall be applied,” and that create a mandate, not a liberty, giving a district court a non-discretionary duty to perform.

“[I]mmediately following the verb we find an infinitival phrase (“to satisfy the amount of attorney’s fees award”) that specifies the purpose or am of the verb’s non-discretionatory duty,” Gorsuch wrote.

“… we know that when you purposefully seek or aim ‘to satisfy’ an obligation, especially a financial obligation, that usually means you intend to discharge the obligation in full,” he continued. “Together then, these three clues suggest that the court (1) must apply judgment funds toward the fee ward (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 to satisfy the fee award, without of course exceeding the 25 percent cap.”

In Gorsuch’s view, “if Congress had wished to prescribe a different purpose for the judge to pursue, it could have easily replaced the infinitival phrase …”

He was joined in the majority by Chief Justice John Roberts, and Justices Anthony Kennedy, Clarence Thomas and Samuel Alito.

Justice Sonya Sotomayor filed a dissenting opinion, in which she was joined by Justice Ruth Bader Ginsburg, Stephen Breyer and Elena Kagan.

In crafting her dissent, Sotomayor also focused on the specific wording of the statute, focusing on its use of the word “portion.”

The justice notes that the statutory language states “a portion of the judgment (not to exceed 25 percent) shall be applied to satisfy the amount of attorney’s fees awarded against the defendant.”

“[I]t’s statutory context makes clear that the provision permits district courts to exercise discretion in choosing the portion of a prisoner-plaintiff’s monetary judgment that must be applied toward an attorney’s fee award, so long as that portion is not greater than 25 percent,” Sotomayor wrote.

“The cruz of the majority’s reasoning is its definition of the inifinitive ‘to satisfy’ … But the phrase ‘to satisfy’ as it is used in § 1997e(d) does not bear the weight the majority places on it,” she continues. “Its neighboring text and the realities of prisoner-civil-rights litigation rebut the conclusion that ‘to satisfy’ compels a district court always to maximize the amount of the prisoner-plaintiff ’s judgment to be contributed to the fee award, and instead indicate that the only work ‘to satisfy’ does in the statute is to direct a district court to contribute some amount of the judgment toward payment of the fee award.”

 

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