Seven parolees, including Stephanie Gasca, sued Missouri corrections officials in 2020, claiming the state's parole revocation procedures violated due process rights. The district court certified a class of all Missouri parolees who 'currently face, or who in the future will face, parole revocation proceedings' and ordered procedural changes to the Missouri Department of Corrections' practices.
Circuit Judge Kobes wrote that the PLRA's prisoner definition clearly applies because parole revocation proceedings begin with the parolee's arrest and detention. 'Because revocation proceedings begin with the parolee's arrest, and because the plaintiff class includes only parolees who face or will face revocation proceedings, anyone fitting the class description also fits the PLRA's definition of prisoner,' Kobes explained, rejecting arguments that the fee cap shouldn't apply to parolees who aren't currently detained.
The district court had twice rejected the state's argument that PLRA fee caps applied, awarding attorneys' fees in January 2024 and again in January 2025 after monitoring MDOC's compliance. The Eighth Circuit also found that MDOC's appeal was timely because the 2024 fee award was only an interim award that couldn't be immediately appealed, despite the parolees' arguments that the appeal was too late.
The ruling sends the case back to the district court to recalculate the fee awards under PLRA's stricter limitations, which generally tie attorneys' fees to monetary judgments rather than allowing full market rates. The decision could affect other prisoner rights cases where attorneys seek fees for monitoring compliance with court orders.