Spotlight on: Raymond C. Walen, Jr

From the February 2024 Criminal Defense Newsletter

You have been incarcerated since the early 1980s. What do you want people to know about the person you are today, and how have you changed over the years?

When I came to the Reception Center in Jackson, the classification report noted that I had several tickets in the county jail and described me as a “rebellious, resentful, non-conforming individual” who suffered from “lack of a well integrated identity with adequate long range plans.” It emphasized my “association with dyssocial peers.” Indeed, between the ages of 17 and 27 I identified with a peer group that led to run-ins with the law nearly every year. Since I’ve been in prison, my primary and reference groups have changed, due in large part to educational and work opportunities.

I was lucky enough to attend Northern Michigan University when I was in the Marquette Branch Prison and Jackson College and Spring Arbor University when I was in the State Prison of Southern Michigan (SPSM) in Jackson. I later earned mechanic certifications for automobile, motorcycle, and heavy-duty truck repair. In June 2018, I was accepted into the Calvin Prison Initiative Program operated by Calvin University at the Handlon Correctional Facility (MTU) in Ionia. I graduated in May 2023 with a Bachelor of Arts degree. Now I work as a tutor at the Hope-Western Prison Education Program operated by Hope College and Western Theological Seminary at the Muskegon Correctional Facility (MCF). But the biggest influence on my life and outlook was the experience of working for 21 years for Prison Legal Services of Michigan, Inc. (PLSM), a private non-profit law firm with offices inside certain Michigan prisons, including SPSM. About five years into my prison sentence, attorney Sandra Girard hired me as a paralegal. Because our clients saw what we did 24 hours a day, working for PLSM required that we be on our best behavior lest the office lose its credibility. This led to a big change in my primary and reference groups. As I interacted with clients, lawyers, and court staff, I began to see myself as something other than a “criminal,” and I like to think that others did too. My friends in prison were now people who tried to do the right thing rather than seeking notoriety. I realized that, even in prison, people know right from wrong and respect those who do the right thing.

What’s the importance or impact of sharing your story? Is sharing helpful to you? To others?

I hope to convey that people can and do change. It is helpful and hopeful to me because I see others changing. On the other hand, I know that many will never be reached until it’s time because when I was young there was nothing anyone could tell me, although many tried.

You were one of the plaintiffs who initially filed and prosecuted Cain, et al. v MDOC, and you worked on the case as a paralegal after Prison Legal Services got involved. In your opinion, what is the most impactful change from the Cain litigation?

The most impactful areas of change are classification, access to courts, and property. In terms of classification, although the MDOC annually screens everyone to determine their proper security classification level, at the time we filed Cain, according to a report by Michigan’s Auditor General, fewer than 25% of those in prison were placed at the level to which they screened. That has changed; now most people in prison seem to be placed in the level to which they screen. Shortly before we filed Cain, MDOC followed a national trend and opened a Level 6 “Supermax” prison, supposedly to house the “worst of the worst.” Yet when our experts interviewed men there and reviewed their files, they learned that many had been diagnosed with a serious mental illness either before or during incarceration. It turned out that they weren’t incorrigible, just untreated. The settlement set up a working group to reach a resolution of how to deal with Level 6; the group came to a consensus that Level 6 should be abandoned, and it was.

In terms of property, at the time we filed Cain only those who worked on the yard crew were issued long johns, winter hats, and gloves. The resolution involved a change in MDOC policy under which everyone now gets those items. The settlement also allowed those of us who can afford it to continue to buy our own winter coats and gloves, items the MDOC wanted to forbid.

On access to courts, the minimum law library collection expanded, the legal writer program was expanded state-wide, legal property protections are now in MDOC policy, and those of us who had typewriters may keep them and those who need one may buy one.

But the more things change, the more they stay the same. For example, under the settlement in Cain we could buy typewriters with a memory that held 50 pages of text. This made both editing and printing multiple copies much easier. But the settlement expired in 2005 and, since 2009, the only typewriter we are allowed to buy has only a one-line correction memory and costs $360. The settlement set the price of photocopies at $0.05 per page, leaving the MDOC about a 25% profit margin. When it expired, they raised the price to $0.10 per page, increasing their margin to about 300%.

MDOC policy1 requires that each law library contain the current edition of Michigan Court Rules. Yet MTU had only a 2020 edition until earlier this year. When I arrived at MCF in June 2023, the law library had the 2021 edition of Michigan Rules of Court – State. When the library committee of the Warden’s Forum2 asked in August 2023 that this be brought up to date, the reply was: “Per policy the law library shall be inventoried every 6 months. This has been done.” A 2023 edition of Michigan Rules of Court – State was finally received on November 22, 2023.

The “legal writers” receive a minimal amount of training, so the skill level varies widely, and that is compounded by the lack of substantive supervision. For example, while the pleadings they prepare are sent to a law firm to be reviewed, there is no attorney review of the source documents on which they are based, and from a LEXIS search it appears that the firm does not have a criminal post-conviction, federal habeas corpus, or civil rights practice, causing one to wonder what is the point of paying that firm nearly $300,000 this year?

The only “personal” winter coat we are allowed to buy is manufactured by Michigan State Industries; with no hood or drawstring, it is not suitable for Michigan winters, and the gloves now sold to us provide little protection below 50°F.

And while the expansion of the Residential Treatment Program (RTP) helps to keep those with functional/behavioral concerns in a better setting than segregation, my five years at MTU – where about half of the population is in RTP – suggests that there is a long way to go to get some of the custody staff on board with that whole concept.

Are there any legal resources not available to people in Michigan prisons that you think would be helpful to have?

Yes. Books, forms with instructions, help from knowledgeable people, and access to Michigan’s Freedom of Information Act.

More than a century ago the United States Supreme Court described the right of access to courts as “the alternative of force.”3 But for those in prison, the Court later limited the constitutionally protected right of access to courts to fact and conditions of confinement;4 it ignored that they are just the tip of the iceberg. People in prison have the same kinds of legal problems as people outside of prison, including divorce, parental rights, visitation, custody, support, personal injury lawsuits, bankruptcy, deportation, and SSI and veterans’ benefits. Yet the MDOC provides no resources in these areas, our law libraries have few if any books on these subjects, and there is little chance of those in prison getting reliable assistance with them.

Many people in prison, provided with the right forms and a little help, can prepare and file papers in court. For more than thirty years, PLSM provided forms in many of these areas but, since it closed in 2008, there is no reliable source for these forms and instructions. The “legal writer” program provides limited assistance in the areas of fact and conditions of confinement only to those who are unable to read or write or are in segregation. Any other people who think they have a claim but are not eligible for that assistance need “the opportunity to consult with a person of good common sense and experience”5 to determine “whether a colorable claim exists.”6

In the context of criminal cases, new evidence of one’s innocence is the key to getting help from one of the conviction integrity units or innocence clinics. In 1994, Michigan’s legislature barred the incarcerated from receiving information under Michigan’s Freedom of Information Act. The only way to get information from the government agencies involved in a case is to have someone outside of prison make the FOIA request. But in most cases the bureaucracy is too complicated for even the most well-intentioned family members and friends to negotiate, even if they have the time, and few in prison have the money to hire a private investigator or a lawyer to do it. In conditions of confinement cases, FOIA is fundamental for those seeking systemic changes to show that a problem in prison is widespread or that their injury was due to deliberate state action rather than a random and unauthorized7 or negligent8 act.

House Bill 4427 will not help with these problems as it only allows those in prison to request and receive a very limited class of records, i.e., those that are not exempt under Section 13 of FOIA, and that meet two additional conditions. First, the requested record must contain “1 or more specific references to the incarcerated individual or the individual’s minor child with whom the individual has not been denied parenting time ... and the record is otherwise accessible to the individual by law.” Second, the requested record must be “related to the arrest or prosecution of the incarcerated individual or the individual’s minor child...”

So even if this bill passes, if you are trying to make a conditions of confinement case that requires proof that adverse conditions affect more than just you, you won’t be able do it through FOIA. And if you’re person A who was wrongfully convicted, it appears that you will not be able to get a record showing that person B told police that persons C and D committed the crime – or any lab reports, photos, or any other type of potentially exculpatory evidence, because those records will almost never refer specifically to you. The solution to these problems is simply to repeal the 1994 amendments to FOIA--MCL 15.231(2) and 15.232{g)-without adding any other hurdles.

What kind of issues do older people in prison face and how can folks on the outside help them?

Older people in prison face the same issues with aging as older people outside of prison—reduction in activities of daily living, declining health, and loss of contact with others as their families and friends age. In addition, like people outside of prison, if they are perceived as being alone, they may fall prey to exploitation by others. These problems are exacerbated by rules that have the effect of limiting contact with family and friends. For example, when in 2009 the MDOC prohibited people in prison from writing to one another except for co-plaintiffs or plaintiffs and witnesses in filed court cases, one man said, “I’ve been locked up more than thirty years, my family is all dead, the only friends I have are in prison. Who am I supposed to write to?”9

Prisons have always isolated us from society, but the trend is to more isolation. For example, while we have an e-mail service through, many older people outside of prison don’t use this kind of technology. We are limited to buying twenty stamps every two weeks. We’re limited to calling twenty different phone numbers per quarter. Visiting lists—for those who can get visits—are limited to ten people other than immediate family; and nieces, nephews, and in-laws are not counted as immediate family. Physical visiting restrictions also serve to isolate people in prison. For example, before COVID the MCF visiting room was set up to handle between twelve to twenty groups of visitors at a time. When COVID hit, in-person visits were eliminated in favor of video visits. People wishing to visit us on video had to sign up online. My 90-plus year-old mother wasn’t tech-savvy enough to set that up, so one of my siblings had to make the arrangements. A lot of older people don’t have that kind of help. Since COVID passed, the COVID protocols here have been eliminated – except for visiting: in-person visiting has been restored, but now it limited to eight groups of visitors-far fewer than before – and those wanting to visit have to sign up online.

We face a $5 co-pay on health care in most situations. Most prison jobs pay about $20 per month so the co-pay is about a week’s pay, and for older people who can’t work, the co-pay is placed as an institutional debt on their account and collected from any money that happens to come in. Michigan’s prisons have the highest percentage of people over 50, and nearly half of the intake population needs immediate follow-up for health or mental health issues.10

In addition to encouraging legislators and the executive to change the practices I described above, there are three ways people on the outside can help. Encourage Governor Whitmer to direct the Parole Board to send her candidates for commutation and grant commutations of older people who have served long sentences. Encourage your legislators to pass the Second Look bills, Senate Bills 321-325 and House Bills 4556-4560. And people can attend and watch what goes on in the courts and at Parole Board hearings. According to Jocelyn Simonson, “court watchers” in New York, Philadelphia, Los Angeles, and Baton Rouge report what social scientists call the observer effect-that they are changing the proceedings just by being there because “[p]eople change their behavior when they know they’re being watched,” as the observers’ presence makes “the silent argument that those accused of crimes are people, too.”11

What are some misconceptions people on the outside have about prisons and the people in them?

In many cases, the difference between people in prison and those outside comes down to life chances and choices. Many people in prison have not had what sociologists would call great life chances. For example, I talked with one man who after his release told me he was making $1,000 a week as a painter. He said, “If I had known it was this easy to make money legally, I never would have become a criminal.” All people have made bad choices—most don’t lead to prison—but making bad choices doesn’t necessarily mean they’re bad people.

It’s also important to understand that most people in Michigan’s prisons aren’t the young, healthy, muscle-bound thugs commonly portrayed in the popular media. To the contrary, a 2019 Michigan House Fiscal Agency Analysis reported, “[a]mong the states, Michigan has the highest percentage of prisoners older than 50,” with 49% of the intake population requiring immediate supplemental medical follow-ups having come to prison with various health or mental health issues.12

The most positive features of people I’ve met in prison are hope, resilience, and personal strengths despite having been subjected to a very negative environment. Hopefulness survives in most here despite the situation: hope for contact with family and friends, for release, and for a better life both in and out of prison. Beyond that, people are resilient. More than half the men I’ve met in prison survived the foster care system as children, something I can’t begin to imagine; most have overcome terrible experiences to become pretty good people who in the past made some bad decisions. Everyone here has strengths; unfortunately, most have had to come to prison to recognize them. Some of the most creative and talented people I’ve known are those I met in prison: artists, musicians, carpenters, mechanics, plumbers, appliance repairmen, you name it. And they had no idea they could do these things until they came to prison.

What are some things every trial lawyer should know or do when their clients are sentenced to prison? What are some things every appellate lawyer should know when working with incarcerated clients?

Four things: get all the information you can on the case, encourage people to start preparing for release the day they get to prison, remember that their situation is one you probably will never fully understand, and read Pleading Out: How Plea Bargaining Creates a Permanent Criminal Class, by Dan Canon (Basic Books, 2023).13

Your clients will tell you what they know; the government will tell you what they think you need to know; and there is always more. Do NOT rely solely on what you or a prior lawyer got on discovery. At both trial and appellate levels, use private investigators and experts and make FOIA requests to every agency and laboratory that might have been involved in the case. The prosecution has far more resources than you do: the whole police machinery. FOIA will help you get the parts of their investigation you didn’t get on discovery (yes, that happens), and your investigators can talk to witnesses to put that information in context and ask questions that their investigators didn’t. Read the report of the Michigan Forensic Science Task Force, and have an expert look at every potentially contested part of the case-you can bet the other side has! And even if your client tells a story that sounds absolutely crazy, follow up on it. One private investigator told the story of a client who claimed he was in a lineup in front of a chalkboard on which an arrow had been drawn pointing down at him. A photo of the lineup that had not been provided to trial counsel showed this to be true and he got a new trial.

Encourage people to start NOW to prepare for release even if it is potentially years away. The Reception Center will evaluate them and make recommendations that may include work, school, counseling, or all three. TelI them to be persistent in trying to get into all recommended programs and get them done! Fulfilling these recommendations and avoiding tickets will help to determine whether their parole guidelines score is high probability, average, or low probability. Nobody with a low probability score ever got a parole. Encourage clients to get into any other programs they can-AA, NA, Celebrate Recovery, NLA, church programs, trades programs, and college programs. Former federal warden Chuck Montgomery wrote the best book on the importance of programming, Beyond Incarceration. While I disagree with some of his ideas—we have different perspectives—I fully support his argument that, because more than 95% of those in prison will be returned to society, we must look “beyond incarceration” to help people develop the skills and worldview that will help them to make it in society without coming back to prison.

Remember that we in prison live in a world that you will never fully understand until you live or work in a prison every day, and many of us do not fully understand your world, so please do not discount your clients’ feelings or perceptions. Keep in mind that people in seemingly hopeless situations often vent their frustration with the system on those who are trying to help them because there is no other safe place to vent them, so don’t be discouraged by complaints, personal attacks, sharp language, grievances, or lawsuits. Those may be more a reflection of the hopelessness people feel than the quality of your work. Be a non-anxious presence. Address your clients’ questions and concerns honestly and promptly. Remember that they have nobody else to rely on but you. If you read this paragraph and think, I’m not a social worker, then ask yourself whether you’re seeing yourself and your clients as simply pawns in what Alan Dershowitz called “the justice game,” and if so whether you’re really ready to do this work.

Join the Prisons & Corrections Section of the State Bar, MI-CURE, Citizens for Prison Reform,14 Criminal Defense Attorneys of Michigan (CDAM), the National Lawyers Guild (NLG), and the National Association of Criminal Defense Lawyers (NACDL) and make a point to interact with other members. This will help you stay aware of the resources available and issues in prisons. CPR and the Prisons & Corrections Section have liaisons in the MDOC who can help you cut through the red tape if your client is having problems. And subscribe to Prison Legal News, Criminal Legal News,15 and the Abolitionist.16 Other sources of information for clients include AFSC’s Michigan Criminal Justice Program,17 the Michigan Coalition to End Mass Incarnation,18 Safe and Just Michigan,19 and Humanity For Prisoners.20

You have done a lot of writing over the years. Why is writing important to you?

The physical barriers that surround prisons—walls, bars, and fences—are as much to keep people out as to keep people in. No recording devices are allowed in prison, no cameras, no cell phones, so there are no other ways than writing to let the public know what we experience here. I believe it is vitally important to give people in prison a voice. UCLA law professor Sharon Dolovich has observed: “There is in the United States no branch of democratic government in which people in custody are regarded or treated as human beings entitled to respect and protection from harm.”21 Psychiatrist Terry Kupers pointed out that litigation is one way of giving those in prison a voice.22 The limitations and restrictions imposed by the state and federal Prison Litigation Reform Acts now make litigation less likely.23 The only way we have a voice is to write. And so I do.

For example, I wrote about the markup on our store goods.24 Part of the markup goes to the Prisoner Benefit Funds, but the lion’s share goes to the State of Michigan. This amounts to about a 40% tax on our purchases, on top of which we are charged a 6% sales tax on any non-food items. So every time inflation goes up, the markup we pay gets inflated, too. When this began in FY 1990-1991, the rate averaged $21 per person per year, about a month’s pay in prison. This year they are charging more than $3.46 million, which comes to an average rate of about $107 per person – about 5 months’ pay in here – to cover the wages of 33 state employees.25 Adding insult to injury is that our prison wages have not seen an increase since 1991, and in fact over the last few years the pay rate for many jobs has been cut. So they have put the highest tax rate on those least able to pay or oppose it.

I’ve written about many other problems I see in prisons, including failures in the health care and mental health care systems,26 how changes in the disciplinary system make it easier to charge and convict people in prison for misconduct,27 the extortionate rates charged for phone calls from prison,28 how some prison mailrooms reflexively reject mail if the person in the mailroom doesn’t like the topic,29 and the state’s bungling of the COVID pandemic, which resulted in the deaths of more than 150 people in prison.30

But my writing isn’t only critical. I give credit where credit is due. When the Michigan Supreme Court adopted a “mailbox rule” for filings by those in prison,31 new rules for administrative appeals,32 and tolled filing deadlines for those in prisons on “outbreak status” due to COVID,33 I duly credited them. And when in 2018 I got to Handlon Correctional Facility for the Calvin Prison Initiative and saw what that was like, I did not hesitate to praise the MDOC for allowing Calvin University to come into the prison.34

You received degrees in 2021 (Associate’s) and 2023 (Bachelor’s) from the Calvin University Prison Initiative-congratulations! Can you tell readers a little bit about that program? What did you study? Do you have plans for additional study?

I wrote about the Calvin Prison Initiative for the Bar’s Prisons & Corrections Section.35 Former MDOC Director Daniel Heyns was instrumental in helping to get the program started, and current MDOC Director Heidi Washington is also a strong supporter of it: she is the most program-oriented director in my 40+ years’ experience, especially in terms of college, vocational, and reentry programs.

Calvin provides a traditional liberal arts program. At the time I went, they offered a major in Faith & Community Leadership and a minor in Social Work. Now they are offering a double major Faith & Community Leadership and Human Services. They know that most students here have been out of school for many years, and they make every attempt to help students succeed, including offering remedial math and English grammar classes, a computer skills workshop, as well as other activities that are offered at the Knollcrest Campus in Grand Rapids: academic advising, tutoring, rhetoric center, library services, writers’ club, theology club, restorative justice club, and choir.

When I began at Calvin, CPI Director Cioffi promised us not only a degree but a resume as well. Consistent with this vision, a few weeks after I graduated from Calvin, four other graduates and I were transferred to Muskegon to join four previous graduates working as tutors is the Hope Western Prison Education Program (HWPEP), a four-year college program sponsored by Hope College and Western Theological Seminary in Holland MI. The accredited program is in its third year; it offers a bachelor’s degree with a major in Faith, Leadership & Service. Because it is not yet eligible for Penn grants, the HWPEP program is funded entirely by private donations. Like Calvin, Hope has committed many resources to help students succeed. These include academic advising, tutoring, and library services, as well as a writing workshop during winter break. A weekly Homeroom offers training in mindfulness, listening, self-and social-awareness, and how to integrate learning in everyday life. At the 2023 Fall Convocation, a choir of students from all three cohorts sang Hope’s alma mater for the guests, and a professor has donated a Yamaha Clavinova to the music program. Much like my experience at PLSM many years ago, the people who come into the prisons to provide all of college programs strive to help students develop an identity as something other than “criminals” and to give marginalized people a sense of belonging to a greater community. This improves the atmosphere in the prisons and gives everyone a better chance of success on release. Thanks to you all.

Kathy Swedlow
CDRC Manager and Editor


1 Law Libraries, PD 05.03.115 (eff. 10/2/23), ¶ C and Attachment A, ¶ 8.

2 Prisoner Housing Unit Representa-tives/Warden’s Forum, PD 04.01.150 (eff. 10/1/19).

3 Chambers v Baltimore & O R Co, 207 US 142, 148 (1907).

4 Lewis v Casey, 518 US 343 (1996).

5 United States ex rel Stevenson v Mancusi, 325 F Supp 1028 (WD NY 1971).

6 Ward v Kort, 762 F2d 856, 860 (CA10, 1985).

7 Parratt v Taylor, 451 US 527 (1981).

8 Daniels v Williams, 474 US 327 (1986).

9 Raymond C. Walen, Jr., Ban on Prisoner-to-Prisoner Mail Further Isolates Prisoners, In the Struggle, Detroit/Michigan National Lawyers Guild (January 2010).

10 House Fiscal Agency, Legislative Analysis, H.B. 4129, 4130, 4131, & 4132, “Parole for Medically Frail Prisoners,” (06/05/19) at pp 9, 10-11.

11 Jocelyn Simonson, We’re Only Here to Watch: How courtwatchers are shifting the power dynamics in criminal courtrooms, The Nation, 8/21-28/2023, pp 30-33.

12 House Fiscal Agency, Legislative Analysis, H.B. 4129, 4130, 4131, & 4132. “Parole for Medically Frail Prisoners.” 2019) at pp 9, 10-11 ts/2019-2020/billanalysis/House/pdf/2019-HL A-4129-BAB0CE52.pdf (accessed December 26, 2023).

13 Matthew Clair, “Disappearing Juries: The rise of the plea bargain,” The Nation, 10/2-9/2023, pp 39-41 (reviewing Pleading Out).

14 P.O. Box 80414, Lansing, MI 48908; 269-349-0606; or

15 Both organizations can be contacted at P.O. Box 1151, Lake Worth Beach, FL 33460, or online at and

16 P.O. Box 22780, Oakland, CA 94609-2301;

17 124 Pearl Street, Suite 607, Ypsilanti, MI 48197; 734-216-4764; or and

18 3810 Packard Drive, Suite 200, Ann Arbor, MI 48108; or

19 119 Pere Marquette Drive, Suite 2A, Lansing, MI 48912; 517-482-7783; or info@safe&

20 P.O. Box 687, Grand Haven, MI 49417; 616-935-0075; or

21 Sharon Dolovich, The Coherence of Prison Law, 135 Harv L R F 301 (2022).

22 Terry A. Kupers, MD, Prison Madness: The Mental Health Crisis Behind Bars and What Must Be Done About It (San Francisco: Jossey Bass, 1999), pp 202-203.

23 Margo Schlanger, Inmate Litigation, 116 Harv L Rev 1555, 1694 (2003)

24 Raymond C. Walen, Jr., Michigan Prisoners Are Taxed Nearly 40%, In the Struggle, Detroit/Michigan National Lawyers Guild, April 2010.

25 2023 PA 119, 2023-24 Appropriations Bill, Article 2, Section 105. The $107 figure was derived by dividing the cost for these employees by the MDOC population as reported in the MDOC 2022 Statistical Report, p C-11.

26 Angela S. Tripp, Natalie Holbrook, Raymond C. Walen, Jr, Robert R. Walsh, Ph.D., Primary Authors; Penny Ryder, Jack Walen, M.D., Sandra Girard, Contributing Authors, Tolerating Failure: The State of Health Care and Mental Health Care Delivery in the Michigan Department of Corrections. Ann Arbor/Lansing: American Friends Service Committee and Prison Legal Services of Michigan, Inc., December 2007; Raymond C. Walen, Jr., Letter, “Torturing the Vulnerable,” The Nation. June 11, 2012.

27 Raymond C. Wa!en, Jr., “Due Process for Prisoners in the Michigan Department of Corrections?” Prisons & Corrections Forum, Vol. 11, No. 2, Fall 2011.

28 Raymond C. Walen, Jr, “Humpty Dumpty and Prison Telephones.” Prisons & Corrections Forum, Vol. 14, No. 1, Spring 2014.

29 Raymond C Walen, Jr., Letter, The Nation as ‘Security Threat’, The Nation, July 8-15, 2013.

30 Raymond C. Walen, Jr., The Pandemic Response Viewed from the Handlon Facility, Prisons & Corrections Forum, Vol. 20, No. 2, Fall 2020.

31 Raymond C. Walen, Jr., New Court Rules Help Pro Se Litigants, In the Struggle, Detroit/Michigan National Lawyers Guild, July 2010.

32 Raymond C. Walen, Jr., New Court Rules for Appeals from MDOC Hearings Decisions, Prisons & Corrections Forum, Vol. 13, No. 1, Spring 2013; Raymond C. Walen, Jr., Appeals from MDOC Hearings Decisions: Update, Prisons & Corrections Forum, Vol. 18, No. 2, Spring 2018.

33 Raymond C. Walen, Jr., Michigan Supreme Court Administrative Order Aids Access to Courts for Pro Per Prisoners Filing Criminal Appeals During the COVID-19 Pandemic, Prisons & Corrections Forum, Vol. 21, No. 2, Spring 2021.

34 Raymond C. Walen, Jr., This is a Big Deal: The Calvin Prison Initiative Program at Handlon, Prisons & Corrections Forum, Vol. 19, No. 2, Fall 2019.

35 Id.