Bruce v. Samuels, 136 S. Ct. 627

The Prison Litigation Reform Act (PLRA) amended 28 U.S.C. § 1915 in 1996 to require prisoners proceeding in forma pauperis (IFP) to pay filing fees: an initial partial fee equal to 20% of the greater of average monthly deposits or average monthly balance over the prior six months, and monthly installments of 20% of the preceding month's income until the fee is paid.
The statute exempts an initial partial fee when the prisoner has no means to pay and prevents withholding access when the prisoner has no assets or means to pay the initial partial fee.
Antoine Bruce, a frequent federal litigant, challenged the application of § 1915(b)(2) and argued that monthly installment payments should be calculated on a per-prisoner basis (one 20% deduction regardless of number of cases).
The Government and several circuits interpret § 1915(b)(2) to require per-case monthly payments: 20% of monthly income for each case a prisoner has pending.
The D.C. Circuit rejected Bruce's per-prisoner claim and ordered simultaneous monthly payments for each case; the Supreme Court granted certiorari to resolve the circuit split and affirmed the D.C. Circuit.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether § 1915(b)(2) requires monthly installment payments to be assessed per-prisoner (single 20% deduction) or per-case (20% per case)	Bruce: monthly payments should be per-prisoner; language referring to a single "clerk" and administrability favors sequential/per-prisoner deductions	Government: statute is case-focused; paragraph (b)(1) and (b)(2) read together require per-case assessments to deter frivolous prisoner suits	Held: Monthly installments are assessed on a per-case basis; prisoners pay 20% of preceding month's income for each case simultaneously until fees are paid

Neitzke v. Williams, 490 U.S. 319 (1989) (IFP statute ensures indigent access to federal courts)
Woodford v. Ngo, 548 U.S. 81 (2006) (Congress enacted PLRA in response to rise in prisoner litigation)
Jones v. Bock, 549 U.S. 199 (2007) (PLRA designed to filter frivolous prisoner claims)
Bounds v. Smith, 430 U.S. 817 (1977) (prisoners must be provided means to access the courts, e.g., paper and stamps)
Farmer v. Brennan, 511 U.S. 825 (1994) (prison officials' constitutional duty to provide adequate basic needs)
Atchison v. Collins, 288 F.3d 177 (5th Cir. 2002) (adopts per-case approach)
Newlin v. Helman, 123 F.3d 429 (7th Cir. 1997) (per-case approach supports deterrence of multiple suits)
Pinson v. Samuels, 761 F.3d 1 (D.C. Cir. 2014) (case below adopting per-case approach)
Whitfield v. Scully, 241 F.3d 264 (2d Cir. 2001) (adopts per-prisoner approach)
Siluk v. Merwin, 783 F.3d 421 (3d Cir. 2015) (adopts per-prisoner approach)
Torres v. O'Quinn, 612 F.3d 237 (4th Cir. 2010) (adopts per-prisoner approach)