Murphy v. Smith

Under 42 U.S.C. §1997e(d)(2), a district court must use as much of a prisoner’s judgment as necessary, without exceeding 25%, to discharge an award of attorney’s fees.

In a federal civil rights suit, the district court awarded Petitioner with a judgment against two of his prison guards, collectively “Respondents,” including attorney’s fees. Pursuant to 42 U.S.C. §1997e(d)(2), which states that “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 that Petitioner pay 10% of his judgment toward the attorney’s fees. Respondents were responsible for the remaining amount. The Seventh Circuit reversed, holding that the statute requires a district court to exhaust 25% of a prisoner’s judgment before ordering defendants to pay. Upon reviewing the statute in dispute, the U.S. Supreme Court held that the statute requires a district court to apply the judgment toward the attorney’s fees with the purpose of fully discharging the attorney’s fees. The district court must use as much of the judgment as necessary to discharge the attorney’s fees, without exceeding the 25% cap. Upon examining the statutory text, the Supreme Court first concluded that the phrase “shall be applied” indicates a nondiscretionary duty of the district court. Second, the phrase that immediately follows, “to satisfy the amount of attorney’s fees awarded,” specifies the aim of the nondiscretionary duty. Third, dictionary definitions indicate that “to satisfy” means to discharge an obligation in full. The context and surrounding provisions of the statute support this conclusion. AFFIRMED.