## Facts

- Michigan prisoners brought two federal class actions (1977 and 1980) under 42 U.S.C. § 1983 challenging prison conditions.
- The prisoners prevailed, and the district court entered remedial decrees and awarded attorney’s fees under 42 U.S.C. § 1988 for post-judgment monitoring of compliance.
- The district court set market rates and awarded fees semiannually; by April 26, 1996 (the PLRA’s effective date), the approved rate was $150/hour.
- The Prison Litigation Reform Act added 42 U.S.C. § 1997e(d)(3), limiting hourly rates for attorney’s fees in prisoner cases; the cap would reduce the maximum compensable rate in the district to $112.50/hour.
- Fee petitions covered monitoring work performed both before and after April 26, 1996, raising whether the PLRA cap applied to unpaid pre-effective-date work and to post-effective-date work in already-pending cases.

## Issues

1. Whether 42 U.S.C. § 1997e(d)(3) caps attorney’s fees for post-judgment monitoring services performed before April 26, 1996 but awarded or paid after that date.
2. Whether § 1997e(d)(3) caps attorney’s fees for post-judgment monitoring services performed on or after April 26, 1996 in cases filed and pending before the PLRA took effect.

## Decision

- The Supreme Court affirmed in part and reversed in part the Sixth Circuit.
- The PLRA fee cap does not apply to monitoring services performed before April 26, 1996, even if fees were awarded later.
- The PLRA fee cap applies to monitoring services performed on or after April 26, 1996, even in cases pending when the PLRA became effective.
- The case was remanded for recalculation consistent with the distinction between pre- and post-effective-date work.

## Legal Principles

- When a statute lacks an express temporal directive, courts apply the Landgraf framework and avoid applying the statute to completed conduct if doing so would impose a retroactive effect.
- For attorney-fee limits regulating compensation for legal services, the operative event for retroactivity is when the legal services were performed, not when the case was filed or when the fee award was entered.
- Applying a new fee cap to services already performed can create an impermissible retroactive effect by altering the legal consequences of completed work and impairing settled compensation expectations.
- Applying a fee cap to services performed after the statute’s effective date is prospective because counsel can decide whether and how to provide future services in light of the new compensation limit.

## Conclusion

The Court held that § 1997e(d)(3) cannot reduce compensation for post-judgment monitoring work completed before the PLRA’s effective date, but it validly limits fees for monitoring work performed after that date, even in ongoing prisoner-rights cases.


Martin v. Hadix, 527 U.S. 343 (1999)