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Miller v. French

    Brief Fact Summary.

    French and other prisoners sued Miller for cruel and unusual punishment due to conditions in a prison and sought to enjoin a stay of an injunction to correct living conditions in the prison under the Prison Litigation Relief Act.

    Synopsis of Rule of Law.

    Legislation that alters the effect of court cases does not violate the separation of powers.

    Facts.

    French brought a suit against Miller for cruel and unusual punishment due to conditions in the prison. The court enacted an injunction to correct living conditions in the prison. In 1996 after Congress passed the Prison Litigation Relief Act (PLRA), the state of Indiana filed a motion to terminate the injunction, which caused a stay of the injunction under the PLRA. The prisoners sought to prohibit the automatic stay claiming that the automatic stay violated due process and the separation of powers. The District Court prohibited the stay and the Court of Appeals affirmed.

    Issue.

    Whether new legislation that violates court decisions violates the separation of powers?

    Held.

    No. Reversed and remanded. As long as legislation does not completely suspend the decision of the court, the decision does not invade the power of the judicial branch.

    Dissent.

    (Breyer, J.) Federal courts should maintain the authority to enjoin the automatic stay with sufficient justification.

    Concurrence.

    (Souter, J.) The majority was correct in their determination that the PLRA prevents courts from prohibiting the automatic stay, but the issue of the separation of powers should have been left for future cases since they were not addressed in the lower courts.

    Discussion.

    The Separation of powers exists to limit legislation passed that can alter final court decisions. Continuous injunctions, however, are not subject to the separation of powers because it does not alter a final judgment. The PLRA only allows courts to approve an injunction when the relief is necessary, limited, and non-intrusive. Stays against an injunction are automatic and the court has no discretion with regards to enjoining the stay. Failure to enjoin the stay does not violate due process.


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