AELE LAW LIBRARY OF CASE SUMMARIES:
Corrections Law
for Jails, Prisons and Detention Facilities


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Good Time

     Under Mississippi law, a claim challenging the forfeiture of earned good time credit accrued after the prisoner was notified of the forfeiture for an alleged violation of prison rules. The prisoner's failure to make any attempt within a statutory thirty-day time limit to challenge the forfeiture made his claim time-barred. Boler v. Bailey, No. 2002-CP-00838-COA, 840 So. 2d 734 (Miss. App. 2003). [N/R]
     247:99 Retroactive revocation of early release credits, granted to Florida prisoner because of prison overcrowding, violated "ex post- facto" prohibition of U.S. Constitution. Lynce v. Mathis, 117 S.Ct. 891 (1997).
     [N/R] Loss of good time credits following disciplinary proceeding was sufficient to claim federally protected liberty interest, but state law postdeprivation remedies available were adequate in this case. Hamlin v./ Vaudenberg, 95 F.3d 580 (7th Cir. 1996).
     Prisoner's lawsuit seeking restoration of good time credits and parole eligibility was habeas corpus action and exhaustion of administrative remedies was required. Greene v. Meese, 875 F.2d 639 (7th cir. 1989).
     State statute changing goodtime credits can not be applied to inmate whose crime was committed prior to effective date of statute. Weaver v. Graham, 450 U.S. 24, 101 S.Ct. 960 (1981).
     Change in "goodtime" law was only to be applied after effective date of statute. Mitchell v. Rayl, 665 P.2d 117 (Kan. App. 1983).
     Inmate's goodtime credits restored on the basis that he was denied due process at a disciplinary hearing. Wilson v. Smith, 459 N.Y.S.2d 517 (App. 1983).
     Use of summary disciplinary procedures improperly deprived inmates of goodtime credits. Alexander v. Ware, 714 F.2d 416 (5th Cir. 1983).
     Federal court finds that Louisiana inmates have no procedural due process rights prior to the revocation of goodtime credits. McGhee v. Belisle, 501 F.Supp. 189 (E.D. La. 1980).
     Illinois court finds removal of 12 months of goodtime credit for possession of 3.1 grams of marijuana to be unconstitutional. South v. Franzen, 413 N.E.2d 523 (Ill. App. 1980).
     Prisoner's civil rights actions regarding goodtime statute against Oklahoma Attorney General dismissed for failure to state a cause of action. Lee v. Derryberry, 466 F.Supp. 30 (D. Okla. 1978).
     For earlier case discussions see: Woodring v. Whyte, 242 S.E.2d 238 (W. Va. 1978); Hicks v. Lefevre, 399 N.Y.S.2d 928 (App. 1977); Dixon v. Henderson, 493 F.2d 467 (5th Cir. 1974); Taylor v. Schmidt, 380 F.Supp. 1222 (W.D. Wis. 1974); Downes v. Norton, 360 F.Supp. 1151 (D. Conn. 1973).

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