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Michigan Prisoner Properly Denied Review of Documents too Numerous to Transport to Him

Jason Mithrandir, Robert Van Horn, John Chapman and Joseph Molinari (Prisoners), all Michigan state prisoners housed in segregation, asked to review Department of Corrections’ (DOC) files, pursuant to the state Freedom of Information Act (FOIA) Mich. Comp. Laws § 15.231 et seq. (Mich. Stat. Ann. § 4.1801(1) et seq.). Because of the volume of documents requested, guards suggested that the Prisoners designate someone to review them and request the ones they wanted. The Prisoners sued in state court to compel disclosure and for damages. The trial court dismissed, and the Prisoners appealed.

On appeal, the Court of Appeals of Michigan found that because the Prisoners were in segregation and ineligible to go where the documents were kept, and because the documents were too numerous to take to the Prisoners, the guards had made a reasonable attempt to accommodate them. Therefore, the Court affirmed the trial court’s dismissal of the case. See: Mithrandir v. Department of Corrections, 164 Mich.App. 143; 416 N.W.2d 352 (1987).

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Related legal case

Mithrandir v. Department of Corrections