United States Fourth Circuit

The district court properly concluded that the provision of the Prison Litigation Reform Act of 1995 (PLRA), which caps the attorneys' fee award that a successful prisoner litigant may recover from the government in a civil rights action at 150 percent of the value of the prisoner’s monetary judgment is constitutional, where: 1) rational basis review applies; 2) under that standard, Congress could have believed that the danger of frivolous, marginal, and trivial claims was real and that a legislative solution was required to equalize prisoner and non-prisoner litigants; and 3) the simple, mathematical formula embodied in the PLRA rationally forestalls collateral fee litigation while ensuring that the incentive provided by an attorneys' fee award still attaches to the most injurious civil rights violations.

Appellate Information

• Decided 11/01/2013
• Published 11/01/2013

Judges

• WILKINSON

Court

• United States Fourth Circuit

Counsel