Gregory Holt v. Michelle Howard, No. 14-3064 (8th Cir. 2015)
Annotate this CasePlaintiff, an incarcerated felon, filed suit against defendants, alleging that the Arkansas Freedom of Information Act, Ark. Code Ann. 25-19-105(a)(1)(B), violates the equal protection and due process clauses of the Fourteenth Amendment. An employee of the police department denied plaintiff's request for information regarding an individual plaintiff had assaulted because the Act only permits an incarcerated felon to request information of public record through an attorney. The court concluded that the district court did not err by granting summary judgment to defendants because the Act does not violate the equal protection clause where the Act's limitation on those who many benefit from the law is rationally related to at least two legitimate government purposes: the prevention of unlawful use of the statute like harassing or threatening a witness or victim and conserving government resources; the Act does not violate plaintiff's due process right to access the courts because he has not shown that he will suffer an actual injury as a result of the Act's exclusion; and the district court did not abuse its discretion in denying plaintiff's Rule 60(b) motions because his claims failed on the merits and he was not entitled to additional discovery. Accordingly, the court affirmed the judgment.
Court Description: Murphy, Author, with Melloy and Smith, Circuit Judges] Prisoner case - Arkansas Freedom of Information Act. The provisions of the Arkansas Freedom of Information Act which only permit an incarcerated felon to request information of public record through an attorney are rationally related to two legitimate government interests: (1) to prevent inmates from harassing or threatening victims or witnesses and (2)to conserve government resources; as a result, the Act's limit on who may benefit from the law does not violate plaintiff's equal protection rights; plaintiff's claim that the Act violates his due process right to access the courts fails because he has not shown an injury in fact; for future challenges, plaintiff may obtain the records he seeks by filing a discovery motion with a habeas petition; the district court did not abuse its discretion by denying plaintiff's three Rule 60(b) motions as his claims failed on the merit and he was not entitled to the additional discovery he sought in the motions.
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