Bruce v. Samuels
577 U.S. 82
SCOTUS2016Background
- Prisoners proceeding in forma pauperis must pay an initial 20% filing fee under 28 U.S.C. §1915(b)(1).
- Thereafter, §1915(b)(2) requires monthly payments of 20% of the preceding month’s income to be forwarded until the fee is paid.
- Bruce, a frequent litigant, argued monthly payments should be charged per prisoner across all cases, not per case filed.
- The D.C. Circuit held payments are simultaneous and allocated per case, not sequentially per prisoner.
- §1915(b)(4) provides a safety valve preventing deprivation of access to courts for prisoners with no means to pay the initial fee.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether §1915(b)(2) requires simultaneous payments per case. | Bruce advocates per-prisoner payments. | Government advocates per-case payments. | Per-case simultaneous payments. |
| Does the text-context support treating multiple fees per prisoner differently for subsequent installments? | Per-prisoner interpretation better serves deterrence. | Per-case better aligns with single-case focus of §1915. | Statute supports per-case, simultaneous installments. |
| Is the safety valve §1915(b)(4) capable of preserving access to courts under the per-case regime? | Guard against denial of access due to fees. | Value of access preserved; provisions sufficient under per-case. | Yes; safety valve remains applicable under per-case. |
Key Cases Cited
- Neitzke v. Williams, 490 U.S. 319 (U.S. 1989) (explanation of IFP purpose and screening)
- Newlin v. Helman, 123 F.3d 429 (7th Cir. 1997) (discussed as part of deterrence rationale for PLRA)
- Walker v. O’Brien, 216 F.3d 626 (7th Cir. 2000) (discussed in context of multiple filings and fees)
- Lee v. Clinton, 209 F.3d 1025 (7th Cir. 2000) (overruled part of Newlin; affects fee context)
- Bounds v. Smith, 430 U.S. 817 (U.S. 1977) (free postage and access to courts for inmates)