Miller v. French

French and other inmates (plaintiffs) won a 1975 class-action injunction against prison officials, including Miller (defendant), the Superintendent of Pendleton Correctional Facility, over unconstitutional prison conditions; that injunctive relief was still in effect when Congress passed the Prison Litigation Reform Act (PLRA) in 1996, which let states move to terminate injunctions not meeting new statutory standards and imposed an automatic stay of the injunction under section 3626(e)(2) once such a motion was filed. When the state moved to terminate the injunction in 1997, the prisoners argued the automatic stay violated separation of powers and due process; the district court agreed and enjoined the stay, and the Seventh Circuit affirmed that the automatic-stay provision was unconstitutional.