Miller v. French

530 U.S. 327 (2000)

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Nature of the Case

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Facts

In 1975, four inmates at the Pendleton Correctional Facility brought a class and the District Court found that living conditions at the prison violated both state and federal law, including the Eighth Amendment's prohibition against cruel and unusual punishment, and the court issued an injunction to correct those violations. While the State's appeal was pending, the Supreme Court ruled that the Eleventh Amendment deprives federal courts of jurisdiction over claims for injunctive relief against state officials based on state law. On remand, the District Court concluded that most of the state law violations also ran afoul of the Eighth Amendment, and it issued an amended remedial order to address those constitutional violations. The Court of Appeals modified the relief and that injunctive relief has remained in effect since October 1988 with a modification for fire and occupational safety standards. In 1996, Congress enacted the PLRA which establishes standards for the entry and termination of prospective relief in civil actions challenging conditions at prison facilities. P then filed a motion under § 3626(b) to terminate the prospective relief governing the conditions of confinement at the Pendleton Correctional Facility. The prisoner class, French (D), moved for a temporary restraining order or preliminary injunction to enjoin the operation of the automatic stay, arguing that § 3626(e)(2) is unconstitutional as both a violation of the Due Process Clause of the Fifth Amendment and separation of powers principles. The District Court granted D's motion, enjoining the automatic stay. The Court of Appeals affirmed. It concluded that § 3626(e)(2) directly suspends a court order in violation of the separation of powers doctrine under Plaut and mandates a particular rule of decision, at least during the pendency of the § 3626(b)(2) termination motion, contrary to Klein. The Supreme Court granted certiorari.