Brown v. McNeil

Summary

An indigent Florida prison inmate challenged the legality and constitutionality of a Department of Corrections rule requiring payment of copying costs for medical records. The First District Court of Appeal affirmed the denial of declaratory and mandamus relief, holding that the inmate had access to inspect the records and was not constitutionally entitled to free copies.

Holdings

1. An indigent inmate is not generally entitled to free copies of records held by governmental entities, and imposing a copying charge does not deprive the inmate of a constitutional right when the inmate retains access to inspect the records.
2. Brown was not entitled to declaratory judgment or mandamus relief because the rule specifically required payment of copying costs, did not authorize the proposed trust-account lien procedure, and did not preclude inspection of the records.

Questions Presented

1. Whether requiring an indigent prison inmate to pay the copying charge for governmental medical records under Florida Administrative Code Rule 33-601.901(2) violated due process or otherwise rendered the rule unlawful and unconstitutional.
2. Whether Brown was entitled to relief through declaratory judgment or mandamus, including a lien-based alternative to payment of the copying charge.

Disposition

affirmed