Kenneth Lynce v. Hamilton Mathis, Superintendent, Tomoka Correctional Institution, et al. (519 U.S. 433)

U.S. Supreme Court · decided February 19, 1997 · Supreme Court Database (Spaeth)

Citation
519 U.S. 433 · 117 S. Ct. 891
Decided
February 19, 1997
Term
October Term 1996
Vote
9–0
Majority author
Justice Stevens
Issue area
Criminal Procedure
Disposition
Reversed and remanded
Outcome
Petitioning party won
Ideological direction
Liberal
Constitutional ruling
State/territorial law held unconstitutional

Opinion excerpt

Justice Stevens delivered the opinion of the Court. In 1983 and thereafter the Florida Legislature enacted a series of statutes authorizing the department of corrections to award early release credits to prison inmates when the population of the state prison system exceeded predetermined levels. The question presented by this case is whether a 1992 statute canceling such credits for certain classes of offenders after they had been awarded — indeed, after they had resulted in the prisoners’ release from custody — violates the Ex Post Facto Clause of the Federal Constitution. I In 1986 petitioner pleaded nolo contendere to a charge of attempted murder and received a sentence of 22'years (8,030 days) in prison. In 1992 the Florida Department of Corrections released him from prison based on its determination that he had accumulated five different types of early release credits totaling 5,668 days. Of that total, 1,860 days were “provisional credits” awarded as a result of prison overcrowding. Shortly after petitioner’s release, the state attorney general issued an opinion interpreting a 1992 statute as having retroactively canceled all provisional credits awarded to inmates convicted of murder or attempted murder. Petitioner was therefore rearrested and returned to custody. His new release date was set for May 19, 1998. In 1994 petitioner filed a petition for a writ of habeas…

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