David Shinn, Director, Arizona Department of Corrections, et al. v. Shawn Jensen, et al.

The Prison Litigation Reform Act (“PLRA”) prescribes precisely how to calculate an award of attorneys’ fees in prisoner cases. See 42 U.S.C. § 1997e(d). This Court and several circuit courts have recognized that the PLRA’s fee formula, not the traditional lodestar method, applies and limits a district court’s discretion to award more than what it expressly authorizes. The Ninth Circuit, however, followed its own precedent and held that a district court retains the discretion to enhance a fee award, notwithstanding the PLRA’s limitations. The question presented is whether the PLRA leaves any room for a district court to enhance a fee award in prisoner cases beyond what it statutorily prescribes.