Term: 2015
Docket: 14-844
Bruce v. Samuels
- Pro
14-844 BRUCE V. SAMUELS DECISION BELOW: 761 F.3d 1 CERT. GRANTED 6/15/2015 QUESTION PRESENTED: Under the Prison Litigation Reform Act, 28 U.S.C. § 1915(b)(2), prisoners proceeding in forma pauperis must each month pay 20% of their existing income towards a federal case or appeal's filing fee, until satisfying the entire filing fee. The Fifth, Seventh, Eighth, and Tenth Circuits and the D.C. Circuit here have held that, where a prisoner has more than one federal case or appeal for which a filing fee is or remains owed, § 1915(b)(2) requires the prisoner to make a separate monthly 20% installment payment for each such filing fee, meaning that 40% of the prisoner's income would be taken in total per month if the prisoner still has filing fees for two matters outstanding, 60% if he has three filing fees outstanding, and even 100% if he has five filing fees outstanding. The Second and Fourth Circuits, in contrast, have held that § 1915 (b)(2) caps the total to be taken from a prisoner at 20% per month irrespective of how many filing fees that prisoner might still owe, with the prisoner paying off each filing fee sequentially in the order in which it was incurred. The question presented is: When a prisoner files more than one case or appeal in the federal courts in forma pauperis, does § 1915(b)(2) cap the monthly exaction of filing fees at 20% of the prisoner's monthly income regardless of the number of cases or appeals for which he owes filing fees? LOWER COURT CASE NUMBER: 10-5059
In the case of Bruce v. Samuels, 2015, the U.S. Supreme Court ruled that federal prisoners who file multiple lawsuits or appeals must pay separate filing fees for each one under the Prison Litigation Reform Act (PLRA). The plaintiff, Antoine Bruce, a federal prisoner argued that he should be allowed to pay a single monthly installment towards all his court fees rather than paying separately for each case as required by PLRA. However, Justice Elena Kagan writing on behalf of unanimous court rejected this argument stating that PLRA's text and context dictate sequential rather than simultaneous recoupment of multiple filing fees from inmate trust accounts.
In the dissenting opinion for Bruce v. Samuels, Justice Elena Kagan argued that the majority's interpretation of the Prison Litigation Reform Act (PLRA) was incorrect and unfair to prisoners. She contended that under PLRA, a prisoner who files multiple lawsuits or appeals should not have to pay full filing fees for each one simultaneously but rather sequentially. This means they would complete payment for one case before starting on another, making it more affordable for inmates with limited resources. The majority's decision requiring simultaneous payments could discourage legitimate claims due to financial constraints, according to Kagan. Furthermore, she pointed out that Congress intended this law as a deterrent against frivolous lawsuits by prisoners and not as an obstacle preventing them from seeking justice in court.
