Mississippians Educating for Smart Justice, Inc. v. Mississippi Department of Corrections

Summary

The Mississippi Supreme Court held that the Mississippi Department of Corrections' revised lethal-injection execution protocol was exempt from the Mississippi Administrative Procedures Law's notice-and-comment requirements. The court affirmed the denial of the petitioners' requests for declaratory relief, a writ of mandamus, and an injunction, concluding that the protocol was an internal regulation relating only to inmates.

Holdings

1. MDOC's execution protocol was exempt from the Mississippi Administrative Procedures Law and therefore was not subject to MAPL notice-and-comment requirements.
2. The phrase 'directly related only to inmates' limits the direct subjects of the protocol and does not require that every person affected by or involved in implementing the protocol be an inmate.

Questions Presented

1. Whether MDOC's revised lethal-injection execution protocol constituted a rule subject to the Mississippi Administrative Procedures Law's notice-and-comment requirements.
2. Whether the MAPL exemption for regulations or statements directly related only to inmates applied to MDOC's execution protocol.

Disposition

affirmed