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Michigan Prisoner’s FOIA Suit Dismissed Because No Violation Occurred

Ronald Jordan, A Michigan state prisoner, requested documents from a prison office manager (Manager) under the state Freedom of Information Act (FOIA), Mich. Comp. Laws § 15.231 et seq. (Mich. Stat. Ann. § 4.1801(1) et seq.). After several weeks went by, he sued in state court to compel disclosure and for damages. The trial court dismissed, and Jordan appealed.

On appeal, The Court of Appeals of Michigan recognized that the trial court never ordered the Manager to disclose the documents. Thus, Jordan hadn’t obtained them as a result of a court order, a prerequisite for damages awards. And, since the documents had already been disclosed, the remainder of the suit was moot. Therefore, the trial court’s dismissal of the case was affirmed. See: Jordan v. Martimucci, 101 Mich.App. 212; 300 N.W.2d 325 (1980).

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Related legal case

Jordan v. Martimucci