Lawyer fees from prisoner awards
Murphy v. Smith
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.
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
Holding
In cases governed by §1997e(d), district courts must apply as much of the judgment as necessary, up to 25%, to satisfy an award of attorney’s fees. The specific statutory language supports the Seventh Circuit’s interpretation. First, the mandatory phrase “shall be applied” suggests that the district court has some nondiscretionary duty to perform. Second, the infinitival phrase “to satisfy the amount of attorney’s fees awarded” specifies the purpose or aim of the preceding verb’s nondiscretionary duty. Third, “to satisfy” an obligation, especially a financial obligation, usually means to discharge the obligation in full. 844 F. 3d 653, affirmed.
- Result
- Affirmed
The vote
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
Docket activity
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
AI analysis generated: Decision Record
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AI analysis generated: Case Briefing
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Opinion added: Opinion
Brief added: Questions Presented
More questions
- 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.