Ruhl v. The Department of Corrections
35 N.E.3d 982
| Ill. App. Ct. | 2015Background
- Three inmates (Ruhl, Hernandez, Oaks) sued the Illinois Department of Corrections (DOC) via petitions for writ of mandamus, alleging the DOC charged commissary prices above the statutory markup caps in 730 ILCS 5/3-7-2a.
- Section 3-7-2a permits up to a 35% additional charge for tobacco and up to 25% for non-tobacco items; plaintiffs alleged markups exceeded these limits based on an Auditor General report and sought restitution to their inmate trust accounts.
- Plaintiffs pursued prison grievances (Administrative Review Board denied relief); Ruhl also attempted Court of Claims relief before filing mandamus in Will County circuit court; the three matters were consolidated.
- DOC moved to dismiss under 735 ILCS 5/2-619(a)(9) arguing inmates lack standing to enforce §3-7-2a; trial court granted the motion, relying on Fourth District precedent.
- Plaintiffs appealed, arguing Jackson v. Randle was wrongly decided and invoking Hadley; the Third District affirmed dismissal, holding inmates lack a statutory or constitutional right to enforce commissary price caps by mandamus.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Do inmates have standing to enforce §3-7-2a commissary price caps by mandamus? | Inmates (Ruhl et al.) contend §3-7-2a limits DOC markups and thus gives them a right to relief and restitution for overcharges. | DOC argues §3-7-2a does not confer enforceable rights on inmates; inmates lack standing to challenge commissary prices. | Court: No standing; §3-7-2a does not create a private right enforceable by inmates and inmates have no constitutional right to commissary prices. |
| Is mandamus appropriate to compel DOC compliance with §3-7-2a? | Plaintiffs claim mandamus is proper because DOC has a nondiscretionary duty to comply with the statute. | DOC argues plaintiffs cannot show a clear right to relief or nondiscretionary duty enforceable by mandamus. | Court: Mandamus denied—plaintiffs failed to establish a clear right because statute does not confer enforceable individual rights. |
| Does Jackson v. Randle conflict with Hadley v. IDOC such that Jackson should be rejected? | Plaintiffs assert Jackson is flawed and inconsistent with Hadley, implying inmates can enforce statutory provisions. | DOC and court maintain Hadley is distinguishable (Hadley involved interpretation of DOC rules conflicting with statute) and does not address standing to enforce §3-7-2a. | Court: Jackson is not inconsistent with Hadley; Hadley concerned statutory interpretation of administrative rules, not standing to enforce commissary price caps. |
| Do prisoners have a constitutional due process/right to commissary items at set prices? | Plaintiffs suggest due process principles require enforcement of the statute. | DOC contends no constitutional right exists to commissary items or specific pricing; regulations do not create such rights. | Court: No constitutional entitlement to commissary or fixed prices; due process claim fails. |
Key Cases Cited
- Hadley v. Illinois Department of Corrections, 224 Ill. 2d 365 (Ill. 2007) (statutory interpretation: DOC administrative rule conflicted with the Unified Code)
- Ashley v. Snyder, 316 Ill. App. 3d 1252 (Ill. App. Ct. 2000) (prison regulations guide administration and do not necessarily create enforceable inmate rights)
- Glisson v. City of Marion, 188 Ill. 2d 211 (Ill. 1999) (standing doctrine prevents those without an interest from suing)
- Rodriguez v. Illinois Prisoner Review Board, 376 Ill. App. 3d 429 (Ill. App. Ct. 2007) (elements and extraordinary nature of mandamus relief)
- Lacey v. Village of Palatine, 232 Ill. 2d 349 (Ill. 2009) (standard of review for motions to dismiss)