U.S. District Court: DAMAGES, PLRA-Prison Litigation Reform Act.

• Position: Brief Article

Morrison v. Davis, 88 F.Supp.2d 799 (S.D.Ohio 2000). A prisoner who prevailed on a [sections] 1983 excessive force action against corrections officers moved for an attorney fee award and brought an equal protection challenge against the Prison Litigation Reform Act (PLRA). The district court held that the PLRA limit on attorney fees comported with equal protection. The court found that a fee award of $53,000 was not inherently disproportionate to the $15,000 awarded to the inmate and that only $1 of the damages would apply to the attorney fees. The court noted that the prisoner had vindicated a significant Eighth Amendment right and obtained a judgment that would...