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Edens v. Godinez
985 N.E.2d 312
Ill. App. Ct.
2013
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Background

  • 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)
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Case Details

Case Name: Edens v. Godinez
Court Name: Appellate Court of Illinois
Date Published: Feb 25, 2013
Citation: 985 N.E.2d 312
Docket Number: 4-12-0297
Court Abbreviation: Ill. App. Ct.