- Bookmark
- Share
- CaseIQ
STOKES v. FLORIDA DEPT
Factual and Procedural Background
Robert M. Stokes, an inmate in the custody of the Florida Department of Corrections (DOC), challenged a disciplinary proceeding that resulted in disciplinary confinement and the loss of gain-time. He filed a petition in the circuit court seeking extraordinary relief, which the trial court construed as a petition for mandamus relief. The trial court denied the petition and imposed a lien on Stokes's inmate trust account pursuant to section 57.085, Florida Statutes. Stokes then petitioned the District Court of Appeal for a writ of certiorari to review the trial court's order denying relief and the order imposing the lien.
Legal Issues Presented
- Whether the trial court erred in imposing a lien on the petitioner’s inmate trust account under section 57.085, Florida Statutes, following the filing of a petition challenging a disciplinary proceeding.
- Whether the petitioner timely raised the issue administratively regarding the DOC’s failure to obtain a determination by health care staff that the petitioner’s conduct constituted self-mutilation as opposed to a suicide attempt, as required by Rule 33-601.314, Florida Administrative Code.
- Whether the trial court erred in refusing to consider the merits of the petitioner’s claim concerning the DOC’s noncompliance with its own administrative rule regarding self-mutilation determinations.
Arguments of the Parties
Petitioner’s Arguments
- The lien imposed on his inmate trust account was improper under section 57.085 and should be vacated.
- The DOC disciplinary team erred by charging him with self-mutilation without a prior determination by health care staff that his conduct was not a suicide attempt, as mandated by Rule 33-601.314.
- The issue of the DOC’s failure to consult medical personnel was sufficiently raised through grievances filed at the administrative level, including one to the Secretary of the DOC.
Respondent’s Arguments
- The State argued that recent amendments to sections 57.082(5) and 28.246(4) authorized the imposition of the lien on the inmate trust account.
- The trial court found that the petitioner did not timely file a grievance regarding the DOC’s alleged procedural error in charging self-mutilation without medical staff determination.
Table of Precedents Cited
| Precedent | Rule or Principle Cited For | Application by the Court |
|---|---|---|
| Woullard v. Bishop, 734 So.2d 1151 (Fla. 1st DCA 1999) | Mandamus is the appropriate vehicle for review of prison disciplinary proceedings; procedural requirements for raising issues administratively. | The court relied on this precedent to confirm the proper procedural vehicle and to hold that the petitioner sufficiently raised the grievance issue administratively. |
| Holland v. Wainwright, 499 So.2d 21 (Fla. 1st DCA 1986) | Mandamus may compel agency compliance with its rules and performance of ministerial duties. | Supported the court’s recognition that mandamus was appropriate to compel DOC compliance with procedural rules. |
| Plymel v. Moore, 770 So.2d 242 (Fla. 1st DCA 2000) | Mandamus relief in prison disciplinary contexts. | Reinforced the use of mandamus to review prison disciplinary actions. |
| Schmidt v. Crusoe, 878 So.2d 361 (Fla. 2003) | Limits on imposing liens under section 57.085, Florida Statutes. | Used to reject the imposition of the lien on the inmate trust account in this case. |
| Wagner v. McDonough, 927 So.2d 216 (Fla. 1st DCA 2006) | Interpretation of amendments to sections 57.082(5) and 28.246(4) regarding liens. | Court rejected the State’s argument that the amendments authorized the lien, applying the same reasoning here. |
| Krantzler v. Board of County Comm'rs, 354 So.2d 126 (Fla. 3d DCA 1978) | Pleadings are to be construed favorably to the pleader. | Supported the liberal construction of the petitioner’s pro se pleadings and grievances. |
| Tillman v. State, 287 So.2d 693 (Fla. 2d DCA 1973) | Liberal construction of pro se pleadings. | Reinforced the principle that pro se pleadings should be liberally construed in favor of the pleader. |
| Thomas v. State, 164 So.2d 857 (Fla. 2d DCA 1964) | Liberal construction of pro se pleadings. | Applied to support the court’s favorable reading of petitioner’s grievances. |
| Martinez v. Fraxedas, 678 So.2d 489 (Fla. 3d DCA 1996) | Liberal construction of pro se pleadings. | Used to justify the court’s approach to petitioner’s grievances. |
| Eichelberger v. Brueckheimer, 613 So.2d 1372 (Fla. 2d DCA 1993) | Liberal construction of pro se pleadings. | Supported the court’s favorable interpretation of petitioner’s submissions. |
| Chancey v. Chancey, 880 So.2d 1281 (Fla. 2d DCA 2004) | Liberal construction of pro se pleadings. | Reinforced the principle of liberally construing pro se pleadings. |
| Marrero v. Department of Prof I Regulation, 622 So.2d 1109 (Fla. 1st DCA 1993) | State agencies are bound by their own rules. | Supported the court’s rejection of any de minimis characterization of DOC’s failure to comply with rule 33-601.314. |
Court's Reasoning and Analysis
The court first addressed the lien imposed on the petitioner’s inmate trust account under section 57.085, Florida Statutes. It found the lien improper, relying on precedent from Schmidt v. Crusoe and its own prior decision in Wagner v. McDonough, which rejected the State’s argument that recent statutory amendments authorized such liens in this context. Consequently, the lien order was quashed and any funds deducted were to be restored.
Next, the court examined whether the petitioner had timely and sufficiently raised the issue of the DOC’s failure to obtain a health care staff determination distinguishing self-mutilation from a suicide attempt, as required by Rule 33-601.314, Florida Administrative Code. The trial court had held the petitioner’s grievance untimely. However, the appellate court reviewed the record and found that the petitioner’s grievances, including one addressed to the DOC Secretary, adequately raised this issue. The court emphasized the principle that pro se pleadings and grievances are to be liberally construed in favor of the pleader, citing multiple precedents.
The court also rejected any suggestion that the DOC’s failure to comply with the medical determination requirement was a trivial or de minimis violation. It underscored that the requirement for health care staff to make this determination is essential and binding on the DOC as a state agency, citing Marrero v. Department of Prof I Regulation.
Based on this reasoning, the court granted the writ of certiorari, quashed the trial court’s order denying relief, and remanded the case for further proceedings on the merits of the petitioner’s claims.
Holding and Implications
The court granted the writ of certiorari, quashed the trial court’s order denying extraordinary relief, quashed the order imposing a lien on the petitioner’s inmate trust account, and remanded the case for further proceedings.
The direct effect of this decision is that the petitioner’s inmate trust account lien was invalidated and any funds deducted must be restored. Additionally, the petitioner’s challenge to the DOC’s disciplinary proceeding on the basis of procedural noncompliance with its administrative rules must be considered on the merits by the trial court. The opinion does not establish new precedent beyond applying existing principles regarding mandamus relief, statutory liens, and the liberal construction of pro se pleadings.
VAN NORTWICK, J.
Robert M. Stokes, an inmate in the custody of the Florida Department of Corrections (DOC), petitions for a writ of certiorari for review of a circuit court order denying extraordinary relief and an order imposing a lien on petitioner's inmate trust account. We grant certiorari, quash the order imposing a lien and remand the cause.
While the petitioner styled his circuit court petition as a petition seeking certiorari relief, the trial court properly construed it as a petition for mandamus relief. Woullard v. Bishop, 734 So.2d 1151, 1152 (Fla. 1st DCA 1999) (explaining that a petition for writ of mandamus is the appropriate vehicle for review of a prison disciplinary proceeding). Mandamus may lie where a party seeks an agency's compliance of its rules. See Holland v. Wainwright, 499 So.2d 21, 22 (Fla. 1st DCA 1986) ("The writ may be used to compel the performance of a ministerial duty imposed by law where it has not been performed as the law requires."); Plymel v. Moore, 770 So.2d 242 (Fla. 1st DCA 2000).
First, the trial court erred in denying petitioner's motion to vacate the order placing a lien on his prison trust account. The lien was imposed on the authority of section 57.085, Florida Statutes, after petitioner filed his petition in the trial court challenging a disciplinary proceeding which resulted in disciplinary confinement and the loss of gain-time. The lien is not proper. See Schmidt v. Crusoe, 878 So.2d 361 (Fla. 2003). As we did in Wagner v. McDonough, 927 So.2d 216, 217 (Fla. 1st DCA 2006), we rejected the argument made to us by the State that recent amendments to sections 57.082(5) and 28.246(4) authorize imposition of the lien.
As for the issues raised by the petition for extraordinary relief filed below, the trial court ruled that the petitioner did not timely file a grievance with the officials of DOC raising the issue of whether a charge for self-mutilation could have been brought against petitioner without a prior determination that petitioner's conduct (cutting his forearm) was not a suicide attempt. Based on our review of the record, we find that the issue was sufficiently raised at the administrative level and hold that the trial court erred in not passing on the merits of this issue. See Woullard v. Bishop, 734 So.2d 1151, 1152 (Fla. 1st DCA 1999).
Rule 33-601.314, section 9-30, Florida Administrative Code, proscribes self-mutilation, which the rule defines as including "self-disfigurement such as body piercing, scarring and other non-life threatening acts." The rule further provides that the "[d]etermination of whether an act constitutes self-mutilation as opposed to a suicide attempt shall be made by health care staff." (bold added).
Following a hearing, the DOC disciplinary team determined that petitioner was guilty of the charged infraction of self-mutilation. Petitioner thereafter filed a grievance which argued, in part:
Sgt. Clark failed to ascertain a clear understanding of the charge (9/30) self mutalation [sic] — wherefore the appellant was having a "new-crisis" (mental) and not simply indulging in "body art" to which constitutes self-mutalations [sic][.] Had Sgt. R. Clark given the matter some consideration, referred to chapter 33 Rule Infraction Code, and consulted with medical personnel first[,] this report would not have been written.
(Bold added).
After this initial grievance was denied, petitioner filed a grievance with the Secretary of the DOC, in which he argued, in part:
Sgt. Clark simply failed to fully understand or ascertain the situation before his eyes, before deeming it self mutilation. As well as failed to consult with medical. He had plenty of time to do so between the time of the incident at 18:35 and the time of the disciplinary report was written at 20:30. Furthermore, one is not hospitalized on an ISO ward, administered an IV and placed in a SOS cell under suicide watch for tattooing one's body, meaning self mutilation.
(Bold added).
Generally speaking, pleadings are to be construed favorably to the pleader. See Krantzler v. Board of County Comm'rs, 354 So.2d 126, 129 (Fla. 3d DCA 1978). Furthermore, "liberal construction should be given to pro se pleadings." Tillman v. State, 287 So.2d 693, 694 (Fla. 2d DCA 1973); Thomas v. State, 164 So.2d 857, 857 n. 1 (Fla. 2d DCA 1964); Martinez v. Fraxedas, 678 So.2d 489, 491 (Fla. 3d DCA 1996); Eichelberger v. Brueckheimer, 613 So.2d 1372, 1373 (Fla. 2d DCA 1993); Chancey v. Chancey, 880 So.2d 1281, 1282 (Fla. 2d DCA 2004). Mindful of these precepts, we hold that petitioner did sufficiently grieve the issue of whether the DOC erred in not obtaining a determination by health care staff that petitioner's conduct was not a suicide attempt as mandated by rule 33-601.314.
To the extent the trial court may have found any failure on the part of DOC to abide by rule 33-601.314 to be a de minimis violation, we cannot agree. The requirement that the determination of whether an act was self-mutilation must be made by "health care staff" is an essential one, and DOC, as a state agency, is bound by its own rules. See Marrero v. Department of Prof I Regulation, 622 So.2d 1109, 1112 (Fla. 1st DCA 1993).
Accordingly, the petition for a writ of certiorari is granted, the order summarily denying petition is quashed, and the matter is remanded to the trial court for further proceedings. Further, as noted, the order imposing a lien on petitioner's inmate account is also quashed, and any funds deducted from that account pursuant to the lien are to be restored.
BROWNING, C.J., and WOLF, J., concur.
Alert