Duckworth v. French

Summary

        The U.S.C.A. 7th has concluded that the automatic stay provision of the Prison Litigation Reform Act, which had set limits for federal courts to adjudicate state claims for termination of prison injunctions, violated the separation-of-powers doctrine.

        In 1996, Congress passed the Act to reduce the involvement of federal courts in the management of state prisons. In 1997, the state of Indiana filed a motion with the district court to terminate an injunction issued in 1982 to correct conditions at the prison Pendleton Correctional Facility. The injunction set a cap on the prison population; set standards for medical care, food preparation, use of physical restraints, recreation, and non-punitive segregation of prisoners; established due process standards for prison discipline; required provision of substance abuse and mental health services; and established policies for education and training. The state moved to immediately terminate the injunction. The automatic stay provision of the Act gave the district court 90 days to rule on the motion, otherwise the injunction would lose its prospective relief. The prisoners at the correctional facility moved for a temporary restraining order and preliminary injunction against the automatic stay provision. The court ruled that the automatic stay provision of the Act was unconstitutional. The state appealed, and the United States intervened to support the constitutionality of the Act.

        The U.S.C.A. 7th affirmed. The Act, codified at 18 U.S.C. Section 3626, addresses appropriate remedies with respect to prison conditions. It allows courts to issue injunctions governing prison operations. However, a state may file a motion to vacate the injunction. If the court fails to act within 90 days on the motion, then the injunction loses its prospective relief.. Here, United States unconvincingly argued that the Act should not be literally read; instead, it should be loosely read to allow a court to keep an injunction in place indefinitely. This interpretation was inconsistent with the plain language of the Act. However, the automatic stay provision violated separation-of -powers principles because it amounted to a direct legislative suspension of a court order. It essentially placed the power to review judicial decisions outside the judiciary. And, left the power to continue the injunction entirely in the hands of the party that filed the motion for termination. This amounted to an unconstitutional intrusion on the power of the courts to adjudicate cases.

        

        

        

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