The U.S. Supreme Court case Bill Martin, Director, Michigan Department of Corrections v. Everett Hadix et al., 1998 revolved around the issue of whether a federal court could award attorney's fees for post-judgment monitoring work performed before the enactment of Prison Litigation Reform Act (PLRA) but not ordered by the court until after its enactment. The respondents were prisoners who had successfully sued Michigan prison officials over conditions at their facility and were awarded attorney’s fees under Civil Rights Attorney’s Fees Awards Act for post-judgment monitoring work done to ensure compliance with remedial orders. However, when they sought additional compensation for further monitoring services rendered prior to PLRA's passage but not ordered until afterwards, it was denied on grounds that PLRA capped such awards at 150% of money damages received in judgment which was zero in this case since only injunctive relief was granted initially. The Supreme Court held that while Congress intended PLRA to apply immediately upon its passage without exception or grandfather clause protecting pending cases from new fee limitations; however, it did not intend retroactive application affecting pre-enactment conduct thus entitling respondents' attorneys to full compensation.

In the dissenting opinion for the case of Bill Martin, Director, Michigan Department of Corrections v. Everett Hadix et al., Justice Stevens argued that the majority's decision to apply a new law retroactively was unjust and inconsistent with legal precedent. He contended that it violated principles of fairness by changing the rules after they had already been set and agreed upon. The new law in question reduced attorney fees awarded in cases against state governments; applying this change retroactively would significantly decrease compensation previously granted to lawyers who represented prisoners in a class-action lawsuit over prison conditions. Justice Stevens also criticized the majority's interpretation of congressional intent behind this legislation, suggesting they were reading into it more than what was explicitly stated or intended by lawmakers.