Supreme Court of the United States · 2000 · Federal Courts
Federal CourtsSeparation of PowersPrison Litigation Reform ActInjunctionsPLRA18 U.S.C. § 3626(e)(2)automatic stayprospective relief
Facts
Prisoners at Indiana's Pendleton Correctional Facility had long been protected by an ongoing injunction addressing Eighth Amendment violations in prison conditions. After Congress enacted the PLRA, the statute allowed defendants to seek immediate termination of prospective relief unless the relief satisfied specified narrow-tailoring findings, and it provided that a termination motion shall operate as a stay after 30 days, extendable up to 90 days for good cause, until the court rules. The superintendent filed a motion to terminate the Pendleton injunction under § 3626(b). The prisoner class then sought to block the automatic stay, arguing that § 3626(e)(2) was unconstitutional.
Issue
Does § 3626(e)(2) permit a district court to use its equitable powers to enjoin the PLRA's automatic stay? If not, does the automatic stay provision violate separation of powers by suspending or reopening a final judgment or by prescribing a rule of decision?
Rule
Section 3626(e)(2) unambiguously makes the automatic stay mandatory and precludes district courts from enjoining its operation through traditional equitable powers. A statute does not violate separation of powers merely because it alters the legal standards governing prospective relief and requires a stay of relief that is no longer enforceable under the new law; Congress may change the law underlying continuing injunctions without reopening final judgments barred by Article III.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
A federal district court in Ohio has long enforced an injunction regulating conditions at Lakeview Correctional Center in Toledo. After Congress enacts a statute providing that any motion to terminate qualifying prospective prison relief "shall operate as a stay" beginning 30 days after filing and ending when the court rules, prison officials file a termination motion. The judge concludes that the old decree probably remains wise policy and enters an order preserving it during the statutory period based on traditional equitable authority.
How should a court of appeals rule on the judge’s order?
Explanation. The majority held that when Congress unambiguously provides that a termination motion "shall operate as a stay" during a specified period, the stay is automatic and mandatory. A district court may not use traditional equitable powers to "stay the stay," because doing so would convert mandatory language into discretionary language. (Derived from French v. Miller (n.d.).)