Murphy v. Smith

Charles Murphy, an Illinois prisoner who is blind, sued correctional officer John R. Smith and others for excessive force, winning a monetary judgment of $10,000. The district court awarded his attorneys over $108,000 in fees under 42 U.S.C. § 1988 but applied the Prison Litigation Reform Act to require Murphy to pay 10% of the judgment toward attorney fees. The U.S. Court of Appeals for the Seventh Circuit held that the PLRA only limits the portion of the judgment applied to satisfy attorney fees, not the overall fee award, leaving defendants liable for the remainder. The Supreme Court granted certiorari to resolve a circuit split.

In a 5-4 decision authored by Justice Gorsuch, the Supreme Court reversed the Seventh Circuit, holding that the PLRA limits attorney fees to 25% of the prisoner’s monetary judgment. The statute requires that a portion of the judgment, not exceeding 25%, be applied to satisfy the attorney fees awarded, and it does not authorize courts to award fees in excess of that cap; defendants are not required to pay the remainder.

Whether 42 U.S.C. § 1997e(d)(2) of the Prison Litigation Reform Act caps the total attorney fees a prevailing prisoner can recover at 25% of the monetary judgment, or simply requires that no more than 25% of the judgment be used to pay a larger fee award for which the defendant remains fully liable.

The ruling significantly restricts the ability of prisoners’ civil rights lawyers to recover full attorney fees in cases with small monetary damages. It may discourage attorneys from taking on meritorious inmate civil rights claims, thereby limiting access to counsel and judicial remedies for prisoners subjected to unconstitutional conditions or excessive force.