Opinion · Supreme Court of the United States

Miller v. French

530 U.S. 327

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
2000-06-19
Topic
general

How later courts describe this case

  • holding that prospective relief made “in the absence of the required findings” is immediately terminable “regardless of when ordered”
  • ruling that “[p]rospective relief under a continuing, executory decree remains subject to alteration due to changes in the underlying law”
  • concluding that the plain meaning of a provision expressed the congressional intent to displace equitable authority
  • holding that “[p]rospective relief under a continuing, executory decree remains subject to alteration due to changes in the underlying law”
  • holding that a party who seeks a writ of mandamus must show a “clear and indisputable right” to its issuance (citation omitted)
  • ruling that “[prospective relief under a continuing, executory decree remains subject to alteration due to changes in the underlying law”
  • holding that separation of powers doctrine arises out of articles I, II and III of the United States Constitution and "prohibits one branch from encroaching on the central prerogatives of another.”
  • holding that decisions of this Court constitute the “law” of the Territory

Citator

Miller v. French has been questioned or limited by later authorities: relies on overruled authority: 8 L. Ed. 2d 440 (overruled by Rodriguez De Quijas v. Shearson/American Express, Inc.). Read them before relying on it. 589 later decisions cite it.

Authority status
caution
Cited by
589 opinions

Headnotes

  1. Statutory Interpretation — Statutory Construction Where Congress has made its intent clear, a court must give effect to that intent; the canon of constitutional doubt permits avoidance of constitutional questions only where the saving construction is not plainly contrary to the intent of Congress, and a court may not press statutory construction to the point of disingenuous evasion even to avoid a constitutional question. 530 U.S. at 340-341
  2. Statutory Interpretation — Statutory Construction The use of the mandatory term "shall," together with specification of the points at which an obligation begins and ends, normally creates an obligation impervious to judicial discretion. 530 U.S. at 337 (citing Lexecon Inc. v. Milberg Weiss Bershad Hynes & Lerach, 523 U.S. 26, 35)
  3. Civil Rights Law — Automatic Stay The PLRA's automatic stay provision, 18 U.S.C. § 3626(e)(2), is unambiguous and mandates that a motion to terminate prospective relief "shall operate as a stay" from 30 (or, for good cause, 90) days after filing until the court rules on the motion; courts may not exercise their equitable authority to enjoin or suspend the stay, and construing the provision as merely burden-shifting would subvert its plain meaning by converting a mandatory stay into a discretionary one. 530 U.S. at 335-340
  4. Civil Rights Law — Automatic Stay The one-way appeal provision of § 3626(e)(4), permitting immediate appeal only from an order staying, suspending, delaying, or barring operation of the automatic stay, confirms that the stay must operate during the specified period, such that any attempt by a district court to circumvent the mandatory stay is immediately reviewable. 530 U.S. at 338
  5. Civil Rights Law — Automatic Stay Section 3626(e)(3) only permits the starting point of the automatic stay to be delayed for good cause; it does not affect the stay's operation once it begins and does not preserve courts' equitable discretion to suspend the stay. 530 U.S. at 339-340
  6. Constitutional Law — Separation of Powers The Constitution prohibits one branch of the Government from encroaching on the central prerogatives of another; Article III gives the Federal Judiciary the power not merely to rule on cases but to decide them, subject to review only by superior Article III courts. 530 U.S. at 341
  7. Constitutional Law — Separation of Powers Congress cannot vest review of the decisions of Article III courts in officials of the Executive Branch, and legislation that attempts to reopen a final judgment by annulling it constitutes an assumption of judicial power and is forbidden. 530 U.S. at 342-343 (discussing Hayburn's Case and Plaut v. Spendthrift Farm, Inc., 514 U.S. 211)
  8. Constitutional Law — Separation of Powers Prospective relief under a continuing, executory decree remains subject to alteration due to changes in the underlying law; when Congress changes the law underlying a judgment awarding prospective relief, that relief is no longer enforceable to the extent it is inconsistent with the new law. 530 U.S. at 344-346 (discussing Pennsylvania v. Wheeling & Belmont Bridge Co., 18 How. 421 (1856))
  9. Constitutional Law — Separation of Powers Although a remedial injunction is a final judgment for purposes of appeal, it is not the last word of the judicial department where it is subject to the court's continuing supervisory jurisdiction, and it therefore may be altered according to subsequent changes in the law. 530 U.S. at 344-345 (quoting Plaut v. Spendthrift Farm, Inc., 514 U.S. 211, 227)
  10. Constitutional Law — Separation of Powers Section 3626(e)(2)'s automatic stay does not unconstitutionally suspend or reopen an Article III court's judgment; by establishing new standards for prospective relief in § 3626(b), Congress altered the underlying law, and the stay merely implements the change by rendering unenforceable any prospective relief not supported by the required findings. 530 U.S. at 346-347
  11. Constitutional Law — Separation of Powers The prohibition of United States v. Klein does not apply where Congress amends applicable law; a provision that operates in conjunction with new legal standards and imposes the consequences of the court's application of those standards does not prescribe a rule of decision. 530 U.S. at 348-349 (discussing United States v. Klein, 13 Wall. 128, and Plaut, 514 U.S. at 218)
  12. Constitutional Law — Separation of Powers Congress' imposition of a time limit on judicial decisionmaking does not in itself offend the structural separation of powers concerns underlying the Constitution; the PLRA does not deprive courts of their adjudicatory role but provides a new legal standard for relief and encourages courts to apply it promptly. 530 U.S. at 349-350
  13. Constitutional Law — Due Process Whether a statutory time limit is so short that it deprives litigants of a meaningful opportunity to be heard is a due process question, distinct from structural separation of powers concerns; the Court leaves open whether the PLRA's time limit, particularly in a complex case, may implicate due process. 530 U.S. at 349-350