Murphy v. Smith

Justia Summary

Murphy was awarded a judgment in his federal civil rights suit against two prison guards, including an award of attorney’s fees; 42 U.S.C. 1997e(d)(2) provides that in such cases “a portion of the [prisoner’s] judgment (not to exceed 25 percent) shall be applied to satisfy the amount of attorney’s fees awarded against the defendant.” The district court ordered Murphy to pay 10% of his judgment toward the fee award, leaving defendants responsible for the remainder. The Seventh Circuit reversed, holding that section 1997e(d)(2) required the district court to exhaust 25% of the prisoner’s judgment before demanding payment from the defendants. The Supreme Court affirmed. The mandatory phrase “shall be applied” suggests that the district court has some nondiscretionary duty to perform. The infinitival phrase “to satisfy the amount of attorney’s fees awarded” specifies the purpose of the preceding verb’s nondiscretionary duty and “to satisfy” an obligation, especially a financial obligation, usually means to discharge the obligation in full. The district court does not have wide discretion to pick any “portion” that does not exceed the 25% cap. This conclusion is reinforced by section 1997e(d)’s surrounding provisions, which also limit the district court’s pre-existing discretion under section 1988(b).