In Miller v. French, 530 U.S. 327, 349, 120 S. Ct. 2246, 147 L. Ed. 2d 326 (2000), Congress had passed a statute amending the standard for injunctive relief in cases addressing prison conditions and applied that to any future prospective relief, including existing injunctions.
As part of that legislation, Congress provided that, absent good cause, a motion to lift the injunction would act as an automatic stay of continued relief beginning thirty days after a motion to terminate relief was filed until the court had ruled on the motion. Id. at 333-34.
Prisoners who had previously been awarded injunctive relief were faced with a motion to vacate that relief, subject to the automatic stay.
At issue was whether the automatic stay violated separation of powers by precluding Article III courts from exercising their discretion to enjoin operation of the automatic stay provision. Id. at 334-36.
A lower court held that the automatic stay provision violated separation of powers because it prescribed a rule of decision. Id. at 335.
In reversing, the Court held that the law did not violate United States v. Klein by mandating a rule of decision because, "whatever the precise scope of Klein . . . later decisions have made clear that its prohibition does not take hold when Congress amends applicable law." 530 U.S. at 349.
The Court explained that "rather than prescribing a rule of decision, the stay provision simply imposes the consequences of the court's application of the new legal standard." Id.
Thus, while the legislative act in Klein violated separation of powers by dictating that the introduction of evidence of a pardon mandated a particular result regardless of what the evidence was, the act in Miller did not violate separation of powers because the judiciary could still enter any judgment, so long as it made appropriate findings required by the new legal standard. Id.