Woodman v. Department Of Corrections (Opinion on Application - Remand to TC)
Annotate this CaseTwo freelance journalists, Spencer Woodman and George Joseph, brought separate actions at the Michigan Court of Claims against the Michigan Department of Corrections (the MDOC), arguing that the MDOC wrongfully denied their requests under Michigan’s Freedom of Information Act (FOIA). Plaintiffs sought video and audio recordings of a prisoner altercation that resulted in the death of inmate Dustin Szot. The MDOC denied their FOIA requests, claiming the records were exempt from disclosure. Plaintiffs and the MDOC both moved for summary judgment. The Court of Claims ordered the MDOC to disclose the audio recording to plaintiffs and to produce the videos for an in camera review. The trial court permitted the MDOC to submit the videos in a format that obscured the faces of the employees and prisoners in the videos to protect those individuals. However, the MDOC provided the unredacted videos for in camera review. The Court of Claims ultimately ordered the MDOC to disclose the unredacted videos to plaintiffs. The MDOC moved for reconsideration, arguing that it did not need to disclose the videos or, alternatively, that it should have been allowed to redact the videos by blurring the faces of the individuals in the videos. The Court of Claims denied the motion but nevertheless permitted the MDOC to make the requested redactions and permitted plaintiffs’ counsel to view both the redacted and unredacted videos. Plaintiffs challenged the trial court’s reduced amount of attorney fees and the denial of punitive damages. The MDOC cross-appealed, challenging only the trial court’s determination that plaintiffs prevailed in full and thus were entitled to attorney fees under FOIA. The Michigan Supreme Court determined plaintiffs prevailed under MCL 15.240(6) because the action was reasonably necessary to compel the disclosure of the records and because plaintiffs obtained everything they initially sought; accordingly, the court was required to award reasonable attorney fees. Furthermore, pro bono representation was not an appropriate factor to consider in determining the reasonableness of attorney fees; accordingly, the Court of Claims abused its discretion by reducing the attorney-fee award to plaintiffs' law firm on the basis of the firm's pro bono representation of plaintiffs.
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