U.S. District Court: PLRA-Prison Litigation Reform Act PARTIAL SUCCESS.

• Position: Brief Article

McLindon v. Russell 108 F.Supp.2d 842 (S.D.Ohio 1999). A prison inmate brought an excessive force claim against an officer and a deliberate indifference claim against a supervisor and was awarded $201 in damages ($1 actual damages and $200 punitive damages) following a jury trial. The prisoner moved for the award of attorney fees. The district court held that the cap on attorney fees of 150% of the award that was specified in the Prison Litigation Reform Act (PLRA) was not applicable when the fees were greater than 150%, but that a deduction of 25% of the $201 award would be made to offset part of the...