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Tennessee Prisoners Entitled to Submit Public Records Act Requests

Tennessee State prisoner Robin Cole challenged an appellate affirmation of his denial to make Public Records Act (Act) requests. The denial was reversed in the case of first impression.

Cole requested documents from the Commissioner of Corrections regarding a riot at his facility which landed him in administrative segregation. He brought an action to compel when his request was denied. The chancery court ruled that he was not a "citizen" afforded protection under the Act because of his convictions and the judgment was upheld on appeal. Cole challenged the affirmation.

The Supreme Court of Tennessee at Nashville held that "Tennessee does not have a civil death statute, nor does it have a specific disability statute that prohibits a convicted felon from filing a petition under the Public Records Act." The court noted further that no such punishment may be imposed without statutory authority. See: Cole v. Campbell, 968 S.W.2d 274 (Tenn. 1998).

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Related legal case

Cole v. Campbell