McCarthy v. Bronson
Petitioner brought a District Court suit against various state prison officials alleging that, in violation of his constitutional rights, they used excessive force when transferring him from one cell to another. Although he waived a jury trial and initially consented to have a magistrate try the entire case pursuant to 28 U.S.C. § 636(c)(1), petitioner was permitted at trial to withdraw his consent to the Magistrate's jurisdiction. However, the Magistrate ruled that he was nonetheless authorized to conduct an evidentiary hearing and to submit proposed findings of fact and a recommended disposition to the court under § 636(b)(1)(B), which authorizes the nonconsensual referral to magistrates for such purposes "of applications for posttrial relief made by individuals convicted of criminal offenses and of prisoner petitions challenging conditions of confinement." (Emphasis added.) The District Court overruled petitioner's objection to the Magistrate's role and accepted the Magistrate's recommended findings and judgment for defendants. The Court of Appeals affirmed.
Held: Section 636(b)(1)(B) does not, as petitioner contends, permit nonconsensual referrals to a magistrate only when a prisoner challenges ongoing prison conditions, but encompasses cases alleging a specific episode of unconstitutional conduct by prison administrators. Pp. 138-144.
(a) Although the most natural reading of the phrase "challenging conditions of confinement," when viewed in isolation, would not include suits seeking relief from isolated episodes of unconstitutional conduct, § 636(b)(1)(B)'s text, when read in its entirety, suggests that Congress intended to include the two primary categories of prisoner suits—habeas corpus applications and actions for monetary or injunctive relief—and thus to authorize the nonconsensual reference of all prisoner petitions to a magistrate. This interpretation is bolstered by Preiser v. Rodriguez, 411 U.S. 475, 498-499, 93 S.Ct. 1827, 1840-1841, 36 L.Ed.2d 439, which, just three years before § 636(b)(1)(B) was drafted, described the same two broad categories of prisoner petitions and unambiguously embraced challenges to specific instances of unconstitutional conduct within "conditions of confinement." The fact that Congress may have used the latter term to mean ongoing situations in other legislation having a different purpose cannot alter the interpretation of the § 636(b)(1)(B) language that so clearly parallels the Preiser opinion. Moreover, adoption of the Preiser definition comports with § 636(b)(1)(B)'s central purpose of assisting federal judges in handling an ever-increasing caseload. Pp. 138-144.
(b) Petitioner argues that because a prisoner is constitutionally entitled to a jury trial in a damages action arising out of a specific episode of misconduct, it is unlikely that Congress would authorize a nonconsensual reference in such a case to a magistrate who may not conduct a jury trial. This argument is not persuasive. Petitioner's statutory reading concededly would not eliminate in all actions the potential constitutional difficulty he identifies. More important, the statute properly interpreted is not constitutionally infirm in cases like this one, in which the plaintiff waived the right to a jury trial, nor in cases in which the jury right exists and is not waived, in which the lower courts, guided by the principle of constitutional avoidance, have consistently held that the statute does not authorize reference to a magistrate. P. 144.
906 F.2d 835 (CA2 1990), affirmed.
STEVENS, J., delivered the opinion for a unanimous Court.
Christopher D. Cerf, for petitioner.
Richard Blumenthal, for respondents.
Justice STEVENS delivered the opinion of the Court.