Proctor v. White Lake Police Dept.
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Proctor v. White Lake Police Dept. was a case before theMichigan Court of Appeals in 2001 concerning an inmates right to public records requests.
Important precedents
This case established that the Michigan Freedom of Information Act statute that prevents state inmates from making FOIA requests isnot in violation of the text.
Background
- In1995, Proctor was convicted of murder and sentenced to life in prison. He had exhausted all of his appeals.
- OnJune 8, 1998, Proctor submitted a records request to the police department for all documents relating to his investigation and conviction. Proctor stated that he intended to use the information to file a "Motion for Relief From Judgment."
- OnJune 15, the police department denied his request. Proctor resubmitted the request and it was denied again onJune 25. On that same day, Proctor filed suit in circuit court, seeking to compel the release of the documents.
- The circuit court ruled in favor of the police department and the decision was appealed.[1]
Ruling of the court
The circuit court ruled in favor of the police department, arguing that inmates did not have the right to invoke FOIA, an exemption found within the Michigan Freedom of Information Act.
The Court of Appeals affirmed the decision of the circuit court, upholding the law that prevents incarcerated prisoners from making FOIA requests.
The Court of Appeals felt that the clause within the Michigan Freedom of Information Act that prevents convicts from making public records requests did not infringe on Proctor's right to a fair trial. The court went on to establish that the right to FOIA itself was not a constitutional but a statutory guarantee. Finally, the court determined that the clause did not violate due process by only applying to incarcerated prisoners and not freed prisoners, because incarcerated and freed prisoners were of a fundamentally different nature. Based on these factors, the court upheld the decision of the circuit court and determined that the clause preventing incarcerated felons from submitting FOIA requests was not in violation of the constitution.[1]
