Murphy v. Smith
The Supreme Court ruled that when a prisoner wins a civil rights lawsuit and his lawyer is awarded fees, the trial court must take as much as necessary from the prisoner's own money judgment—up to a cap of 25%—before making the losing defendants pay the rest.
The 5-4 decision means prisoners who win judgments against guards or other officials will typically see a bigger chunk of their winnings go toward paying their own lawyer, shifting less of that cost onto the government employees who were sued.
“these three clues suggest that the court (1) must apply judgment funds toward the fee award (2) with the purpose of (3) fully discharging the fee award”
The majority's core reasoning for why courts must maximize the prisoner's contribution up to the cap.
How it got here: A trial court ordered the prisoner to pay 10% of his judgment toward fees; the Seventh Circuit reversed and required 25%; the prisoner asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Charles Murphy, a prisoner who was beaten and choked by prison guards, won a jury verdict and a $108,446.54 attorney's fee award in his federal civil rights suit. A federal law says a 'portion' of a prisoner's judgment, 'not to exceed 25 percent,' must go toward the fee award before the losing defendants owe the rest. The trial judge ordered Murphy to pay only 10%, leaving guards Robert Smith and Gregory Fulk responsible for the balance.
The question before the Court
When a prisoner wins money damages and his lawyer gets a fee award, must the court take the full amount owed—up to 25% of the judgment—from the prisoner before billing the guards who lost the case?
The Court's answer
Yes — the Court ruled that district courts must draw as much money as necessary from a prisoner's own judgment, up to the 25% cap, to pay off the attorney's fee award before requiring the losing defendants to cover any remaining balance. The judge does not get to pick an arbitrary smaller share, like 10%, just because it seems fair under the circumstances.
The Court reasoned that the law's phrase 'shall be applied to satisfy' creates a mandatory duty aimed at fully paying the fee award, not a menu of discretionary options. It also noted that Congress had removed open-ended discretionary language from an earlier version of the same type of fee-shifting law, suggesting lawmakers intended less judicial freedom here than under the general civil rights fee statute.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Prisoners who win civil rights suits will generally have to give up more of their money judgments to pay their lawyers, since courts must draw as much as possible (up to 25%) from the prisoner's award first. That leaves less money in prisoners' pockets and reduces defendants' exposure, which could also affect how willing lawyers are to take these cases.
What changes now
This is a final merits ruling, so the case is over: the Seventh Circuit's judgment requiring Murphy to pay 25% of his judgment toward the fee award stands. Going forward, trial courts across the country handling prisoner civil rights fee awards must apply this same rule, drawing as much as necessary (up to 25%) from a prisoner's judgment before shifting any remaining fee balance to the defendants.
What this does not decide
The ruling addresses only how much of a prisoner's own judgment must go toward attorney's fees under this specific prisoner-litigation statute; it does not change how attorney's fees are calculated in the first place, nor does it revisit the general discretion judges have under the broader civil rights fee-shifting law that applies outside the prison context.
Concurrences and dissents
Dissent — Justice Sotomayor
Justice Sotomayor argued the statute's use of the word 'portion' and the phrase 'not to exceed 25 percent' shows Congress meant to give judges discretion to choose how much of a prisoner's judgment goes toward fees, capped at 25%, not a duty to maximize that amount. She pointed out that because fee awards almost always exceed prisoners' modest judgments in practice, the majority's reading would make judges take 25% in nearly every case, and noted Congress had deleted draft language that would have supported the majority's approach.
How the Court got there
The legal reasoning, step by step
- The Court examined the statute's wording clue by clue: the word 'shall' in 'shall be applied' signals a mandatory duty rather than something left to a judge's free choice.
- It then looked at the phrase 'to satisfy the amount of attorney's fees awarded,' reasoning that when someone acts 'to satisfy' a financial obligation, that ordinarily means fully paying it off, not just chipping away at it.
- Putting those two clues together, the Court concluded the judge must draw money from the prisoner's judgment specifically for the purpose of fully paying the fee award, using as much of the judgment as needed without going over the 25% ceiling Congress set.
- The Court compared this law to the older general civil-rights fee statute, which openly gave judges discretion using words like 'may' and 'reasonable.' Because Congress dropped that discretionary language when it wrote the new prisoner-specific rule, the Court inferred lawmakers meant to remove, not preserve, judicial discretion here.
- The Court also noted that the other parts of this same law limit judges' fee-setting discretion in similar ways, reinforcing that this provision was meant to constrain rather than replicate the old open-ended approach.
- Applying that reading, the Court found no support for the prisoner's proposed alternative—letting judges apportion fees based on how blameworthy the defendant was—because nothing in the statute's text or history supports that approach.