Jackson v. Randle
354 Ill. Dec. 256
| Ill. App. Ct. | 2011Background
- Jackson sued the Illinois Department of Corrections (DOC) and officials alleging the inmate commissary overcharged inmates in violation of 730 ILCS 5/3-7-2a.
- Defendants moved to dismiss in May 2010 citing sovereign immunity and lack of standing to enforce the statute.
- The trial court granted dismissal in August 2010, holding damages were barred by sovereign immunity and that the Court of Claims had exclusive jurisdiction for claims against the State.
- Lack of standing also meant Jackson could not seek prospective relief to enforce 3-7-2a.
- On appeal, Jackson contended the court erred in dismissing, arguing the claim sought equitable relief and that the statute created a private right, while defendants maintained standing was lacking and sovereign immunity applied.
- The Appellate Court affirmed, ruling Jackson lacked standing because 3-7-2a does not create a private right or confer standing for inmates.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does 3-7-2a confer standing to enforce the statute? | Jackson contends the statute provides standing for inmates to enforce | DOC argues no private right or standing is created by 3-7-2a | Jackson lacks standing; no private right conferred |
| Are the claims barred by sovereign immunity or proper forum? | Jackson seeks equitable relief and enforcement; immunity not applicable to equitable claims | Sovereign immunity bars damages; Court of Claims exclusive for State claims | Sovereign immunity not reached due to lack of standing; court did not decide immunity merits |
| Does 3-7-2a create any enforceable private right for inmates? | Statute creates enforceable private rights for inmates | Statute provides guidance for administrators, not private rights | No private right created by 3-7-2a |
Key Cases Cited
- Ashley v. Snyder, 316 Ill.App.3d 1252 (Ill. App. 2000) (statutes and regulations do not create more inmate rights than constitutionally required)
- Glisson v. City of Marion, 188 Ill.2d 211 (Ill. 1999) (standing defined as precluding actions lacking a concrete interest; standing negates a claim)
- Lacey v. Village of Palatine, 232 Ill.2d 349 (Ill. 2009) (2-619 standard; de novo review of dismissal based on affirmative defenses)