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Murphy v. Smith

Updated Sep 4, 2026

In brief

A court must use as much of a prisoner's damages award as needed for attorney's fees, capped at 25 percent.

Where it stands
Decided

Decided 5-4 · February 21, 2018 · Opinion by Justice Gorsuch

What it’s about
This case asked how much of a prisoner’s damages award must be used to pay attorney’s fees in a civil rights lawsuit under 42 U.S.C. § 1997e(d)(2).
Who it affects
Prisoners who win damages in these cases may have up to 25 percent of their award used for attorney's fees. For example, a court cannot choose a smaller share if more is needed to cover the fee award within that limit.

Summary: written with AI from the case record.

Illustration for Murphy v. Smith
Conceptual illustration · AI-generated

What it's about

The Supreme Court held that courts must apply as much of the judgment as needed, up to 25 percent, rather than choosing any lower amount at their discretion.

The case interprets a federal law that limits attorney's fees in lawsuits brought by prisoners.

Question presented

Whether the parenthetical phrase "not to exceed 25 percent" means any amount up to 25 percent (as four circuits hold), or whether it means exactly 25 percent (as the Seventh Circuit holds)?

What the Court decided

The vote

  • Joined the judgment
  • Dissented
  • Wrote an opinion
Majority · 5joined the Court's opinion
  1. Gorsuchwrote the opinion
  2. Thomas
  3. Alito
  4. Kennedy
  5. Roberts
Dissenting · 4disagreed with the result
  1. Sotomayorwrote the dissent
  2. Kagan
  3. Breyer
  4. Ginsburg
5 justices joined the judgment, 4 dissented.

What's next

The docket action is complete. District courts applying this law must follow the Court's interpretation when calculating attorney-fee payments from damages awards.

Documents

2

Docket activity

4
  • New analysis added

    Sep 4, 2026 · Court records

  • AI analysis generated: Case Briefing

    Sep 4, 2026 · Generated

  • Opinion added: opinion

    Feb 21, 2018 · Court records

  • Brief added: Questions Presented

    Court records

More questions

3
What did the Supreme Court rule in Murphy v. Smith?
Courts must use as much of a prisoner's damages award as needed for attorney's fees, up to 25 percent.
Who is affected by Murphy v. Smith?
Prisoners who win damages in covered civil rights cases and their lawyers are affected. Part of the award may pay the lawyer's fee.
What happens next after Murphy v. Smith?
The case is finished. District courts must apply this interpretation when deciding how much of a damages award goes toward attorney's fees.

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Sep 4, 2026Methodology

Court records and filings

Reporting and analysis