Edens v. Godinez
985 N.E.2d 312
Ill. App. Ct.2013Background
- Edens and May, both inmates at Dixon Correctional Center, filed a May 2010 petition for writ of mandamus seeking to force DOC to calculate sentences under a 360-day year.
- Plaintiffs relied on DOC directive No. 01.07.400.II.F.2 claiming it required 360-day-year calculations and would yield earlier release dates.
- DOC moved for summary judgment in December 2010, arguing plaintiffs had no clear right to relief or duty on DOC to act and no authority to support mandamus relief.
- The trial court granted summary judgment after a May 2011 hearing.
- Plaintiffs asserted the directive created a duty and that the calculation violated their rights; the court relied on statutory definitions and rejected the claim, holding no duties or rights created by the directive.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus was proper relief. | Edens/May claimed DOC had a duty to calculate. | DOC had no clear duty or authority to act. | Affirmed summary judgment; mandamus not warranted. |
| Whether the motion for judicial notice should have been granted. | Plaintiffs sought judicial notice of related pleadings. | Not addressing merits since moot. | Moot; denial not reversible. |
| Whether plaintiffs had a constitutional right to the disputed sentence calculation. | Inmates have a constitutional right to the calculation method. | Prison regulations do not confer private rights. | Rejected; no constitutional right to such calculation. |
Key Cases Cited
- Rodriguez v. Illinois Prisoner Review Board, 376 Ill. App. 3d 429 (2007) (mandamus standards for non-discretionary duties)
- Lucas v. Department of Corrections, 2012 IL App (4th) 110004 (2012) (administrative directives do not create duties warranting mandamus)
- Ashley v. Snyder, 316 Ill. App. 3d 1252 (2000) (prison regulations generally do not confer rights; inmates have limited rights)
- Dupree v. Hardy, 2011 IL App (4th) 100351 (2011) (applies Ashley principles to inmate access rights)
