U.S. Appeals Court: PLRA-Prison Litigation Reform Act LIMITATION.

Madrid v. Gomez, 190 F.3d 990(9th Cir. 1999). After numerous constitutional violations were found to exist, prisoners who had sued prison officials were ordered to collaborate with the prison officials to develop and implement a remedial plan. The district court awarded attorney fees to the prisoners for legal services rendered during the remedial phase of the case and the prison officials appealed. The appeals court affirmed in part, reversed in part and remanded. The appeals court held that the attorney fee limitations of the Prison Litigation Reform Act (PLRA) did not apply to attorney fee awards that were entered after PLRA's enactment but which covered services performed prior to its enactment. The court held that PLRA's limitations did apply to services rendered after its enactment, and that PLRA satisfied the equal protection component of the Fifth Amendment. (Pelican Bay State Prison, California)