Richard Paiva v. Lynne Corry

Summary

The Supreme Court affirmed dismissal of the incarcerated plaintiff’s amended complaint seeking declaratory, injunctive, and mandamus relief concerning a Department of Corrections out-of-cell-time policy. Declaratory relief was unavailable because the DOC director, whose interests would be affected, was not joined, and mandamus was unavailable because implementation of the policy involved discretionary functions. The court also noted that the absence of transcripts limited appellate review.