A Collaboration with the University of Pittsburgh

Supreme Court decides case on prisoner filing fees

[JURIST] The US Supreme Court [official website] ruled [opinion, PDF] Tuesday in Bruce v. Samuels [SCOTUSblog materials] that the Prison Litigation Reform Act (PLRA) [materials, PDF] requires prisoners to pay filing fees on a per-case, not a per-prison basis. The particular question in the case was when a prisoner has more than one case or appeal pending, does the PLRA cap the prisoner's filing fee requirements to 20 percent of the prisoner's monthly income. The court stated that for each case that a prisoner files, the PLRA requires that the prisoner pay filing fees for that case. The court reasoned that PLRA generally refers to cases individually and provides instructions on a case-by-case basis. This indicates that a per-case approach is more in line with the intentions of the statute and the PLRA's goal of deterring frivolous claims.

The case arose [Oyez summary] when prisoners in the Special Management Unit (SMU) of the Federal Correctional Institution in Talladega sued the Federal Bureau of Prisons (BOP). The SMU of the prison is for gang-affiliated and other disruptive individuals. The prisoners claimed that the SMU violates the Eighth Amendment since it houses gang-affiliated prisoners but does not separate members of rival gangs. The prisoners moved to proceed in forma pauperis, which would allow them to waive filing fees. The parties engaged in more filings regarding the collection of filing fees and the ability of other prisoners to join the case. The lower court held that the PLRA does not allow the prisoners to completely waive their filing fees, as they must pay a percentage of their monthly income.

About Paper Chase

Paper Chase is JURIST's real-time legal news service, powered by a team of 30 law student reporters and editors led by law professor Bernard Hibbitts at the University of Pittsburgh School of Law. As an educational service, Paper Chase is dedicated to presenting important legal news and materials rapidly, objectively and intelligibly in an accessible format.

© Copyright JURIST Legal News and Research Services, Inc., 2013.