The U.S. Supreme Court case Charles B. Miller, Superintendent, Pendleton Correctional Facility, et al., v. Richard A. French, et al., 1999 revolved around the interpretation of a provision in the Prison Litigation Reform Act (PLRA) of 1996 that automatically stays prisoner release orders pending appeal by prison officials unless a court makes written findings that certain requirements are met. The respondents were prisoners who had won an order requiring Indiana to remedy unconstitutional conditions at its maximum security facility and argued that this automatic stay provision only applied to new orders for prisoner release and not existing ones like theirs. However, the Supreme Court disagreed with their interpretation and ruled against them in a unanimous decision delivered by Justice O'Connor on June 24th, 1999. It held that PLRA's automatic stay provision applies to all prospective relief whether it is issued before or after enactment of PLRA including those involving ongoing population caps ordered as remedial measures for past constitutional violations.

In the dissenting opinion for Miller v. French, Justice Stevens argued that the court majority misinterpreted the Prison Litigation Reform Act (PLRA). He contended that it was not Congress's intent to automatically stay all prospective relief when a motion to terminate is filed under PLRA. Instead, he believed that judges should have discretion in deciding whether or not to grant an automatic stay based on individual circumstances of each case. Furthermore, he expressed concern over potential constitutional issues arising from this interpretation as it could infringe upon prisoners' rights by denying them access to judicial remedies while their cases are pending review. This could potentially lead to situations where unconstitutional conditions persist in prisons without any legal recourse available for inmates during this period.