Lee v. Godinez
13 N.E.3d 214
Ill. App. Ct.2014Background
- Plaintiff Lincoln Lee filed a mandamus petition against IDOC Director Godinez and other officials seeking good-time credits, work release, and electronic home detention based on his domestic battery conviction.
- Trial court denied the petition sua sponte; counsel was appointed later and sought to withdraw under Anders, which the appellate court granted.
- Plaintiff argued 3-6-3(a)(3) of the Unified Code of Corrections authorized discretionary up to 180 days of good conduct credit, and that unwritten rules denied SSC.
- Defendants contended the Director’s discretionary authority permitted denial without a statutory right to SSC and without a required written policy.
- The court acknowledged discretionary nature of these “perks” and held mandamus relief improper absent a constitutional violation or clear statutory duty.
- The decision approved counsel’s withdrawal and dismissed the appeal as lacking meritorious issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandamus lies to compel discretionary SSC under 3-6-3(a)(3). | Lee argues he is entitled to SSC and that denial was abuse of discretion. | Director has sole discretion to award SSC; no right to SSC exists. | No mandamus lie; discretion resides with Director. |
| Whether the 2012 amendments create an ex post facto violation. | amendment violated ex post facto by changing eligibility. | changes are permissive; not punitive; no ex post facto. | No ex post facto violation. |
| Whether denial of work release/electronic home detention supports mandamus relief. | Denial of discretionary programs constitutes abuse of discretion. | Work release and electronic home detention are discretionary; no right to relief. | No mandamus relief for these discretionary programs. |
Key Cases Cited
- Helm v. Washington, 308 Ill. App. 3d 255 (1999) (mandamus requires a clear duty; good-time credit discretionary under 3-6-3(a)(3))
- Guzzo v. Snyder, 326 Ill. App. 3d 1058 (2001) (director’s unwritten policy violated; mandamus available when Director acts contrary to statute/rules)
- Weaver v. Graham, 450 U.S. 24 (1981) (distinguishes discretionary gain time from automatic operation; ex post facto concerns differ)
- Hadley v. Montes, 379 Ill. App. 3d 405 (2008) (electronic monitoring as discretionary tool; informs lack of mandatory relief)