Chyatte v. Kirkegard
2016 MT 273N
| Mont. | 2016Background
- Plaintiff Douglas J. Chyatte, an incarcerated, mobility‑impaired prisoner at Montana State Prison (MSP), challenged MSP/DOC photocopy fees ($0.20 single‑sided; $0.40 duplex) as preventing his access to the courts.
- Chyatte requested a preliminary injunction limiting MSP copy charges to $0.05 per single‑sided page and $0.10 for records‑department copies.
- The First Judicial District Court denied the preliminary injunction, finding Chyatte failed to show irreparable injury.
- Chyatte appealed, arguing the fees effectively denied him access to judicial review and thus violated due process.
- Chyatte submitted additional exhibits on appeal that were not part of the district court record; the Supreme Court declined to consider materials outside the trial record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether plaintiff established entitlement to a preliminary injunction under § 27‑19‑201, MCA | Chyatte: MSP fees bar his ability to make necessary copies, causing irreparable harm and warranting injunction | Defendants: Chyatte failed to show imminent or actual irreparable injury; fees do not create an immediate constitutional violation | Court: Denied — Chyatte failed to satisfy any subsection of § 27‑19‑201; no showing of irreparable injury |
| Whether the copy fee policy denied Chyatte meaningful access to the courts (constitutional claim) | Chyatte: inability to pay for copies frustrated his pursuit of civil rights claims and appellate review | Defendants: No evidence submitted to district court showing an actual or imminent denial of access to courts | Court: Denied — no evidence in the record of an actual or impending denial of access; speculative harms insufficient |
| Whether appellate court may consider exhibits not submitted to the district court | Chyatte: submitted additional exhibits on appeal to support claims | Defendants: record is limited to what was before the district court | Court: Agreed with defendants — cannot consider new evidence on appeal; Frank v. Harding controls |
Key Cases Cited
- Doe v. Cmty. Med. Ctr., Inc., 353 Mont. 378, 221 P.3d 651 (2009) (standard: appellate review of preliminary injunction is for manifest abuse of discretion)
- Sweet Grass Farms v. Bd. of Co. Comm’rs, 300 Mont. 66, 2 P.3d 825 (2000) (provisions of preliminary injunction statute are disjunctive; satisfying any subsection may warrant relief)
- Frank v. Harding, 290 Mont. 448, 965 P.2d 254 (1998) (appellate court will not consider evidence not presented to the trial court)