Pryer v. State, 139 So. 3d 713

Pryer, an inmate, requested documents from the Itawamba County Circuit Clerk under the Mississippi Public Records Act (PRA).
The circuit court denied Pryer’s request, later stating the records did not exist in the clerk’s file and treating the matter as a petition for Post-Conviction Relief (PCR).
Pryer filed a motion to show cause and sought review in this Court, which led to a mandamus action and a circuit-court order denying the motion.
The Court of Appeals affirmed, describing Pryer’s requests as a fishing expedition and holding no such records likely existed.
Pryer sought certiorari to this Court; the Court granted and ultimately affirmed the Court of Appeals’ decision.
The core dispute concerns whether Pryer’s PRA request could be reviewed in an appellate forum and where his proper remedy lies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the circuit court had jurisdiction to treat a PRA request as a PCR petition	Pryer argues the PRA request was a Public Records Act matter, not a PCR petition, and that the circuit court lacked proper jurisdiction to convert or treat it as PCR.	The state contends the circuit court’s actions fall within jurisdiction to deny the records and the appellate path is proper for review.	PRA denial must be reviewed via chancery court; circuit court did not lack jurisdiction to rule, but appellate review of the PRA denial was improper.
Whether prisoners are within the Public Records Act’s scope	Pryer asserts inmates have the same PRA rights as others and may sue for access.	The state’s position is that the appellate avenues apply when denials occur, not inmate-specific access, and PRA review is limited to chancery courts.	Inmates are within PRA’s scope; the proper remedy remains chancery court, not appellate review.
What is the proper remedy and forum when PRA access is denied	Pryer may obtain public records through PRA litigation in chancery court; the appellate courts should not entertain an original PRA action.	The appellate system should review denials; the circuit court order constitutes an appealable ruling under the court’s view of jurisdiction.	The sole remedy for a PRA denial is an original action in the chancery court; neither this Court nor the Court of Appeals has jurisdiction to hear an original PRA action.

Illinois Cent. R. Co. v. Dodd, 105 Miss. 23 (Miss. 1913) (appellate jurisdiction revises only existing proceedings, not creates a cause)
Fleming v. State, 553 So.2d 505 (Miss.1989) (prisoners must show need or necessity to obtain post-conviction discovery)
Pryer v. State, 139 So.3d 719 (Miss.Ct.App.2013) (Court of Appeals described PRA requests as fishing expeditions)