Bradham v. State

480 N.W.2d 28, 1992 Iowa Sup. LEXIS 20, 1992 WL 6979
CourtSupreme Court of Iowa
DecidedJanuary 22, 1992
Docket90-1502
StatusPublished
Cited by1 cases

This text of 480 N.W.2d 28 (Bradham v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Iowa primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bradham v. State, 480 N.W.2d 28, 1992 Iowa Sup. LEXIS 20, 1992 WL 6979 (iowa 1992).

Opinion

LAVORATO, Justice.

In this consolidated postconviction relief action, three applicants challenge the way the Iowa Men’s Reformatory administers the work bonus day credits program at the institution under Iowa Code chapter 903A (1989). We affirm in part, reverse in part, and remand with directions.

I. Factual Background.

Kurtis L. Bradham, Robert A. Davis, and Timothy G. Lyon are inmates at the Iowa Men’s Reformatory. All three were em *29 ployed at the facility in various jobs. Their evaluations for work performance ranged from above average to outstanding.

Based on their performance evaluations, each applicant earned two or three work bonus day credits per month. These work bonus day credits reduced their time served by one to one and one-half days per month rather than by the two or three work bonus day credits earned.

The applicants challenge two particular policies on how the work bonus program is administered. They complain because the reformatory cuts their work bonus day credits earned in half when calculating their discharge date. They think the reformatory’s method of calculation violates the plain meaning of Iowa Code section 903A.2, the controlling statute on good conduct time and work bonus day credits. And they complain that as inmates living and working in the institution the maximum bonus day credits they can earn is three days a month. They think this policy likewise violates the plain meaning of section 903A.2 which allows “up to five days a month.” Iowa Code § 903A.2.

II. Procedural Background.

Each applicant filed an administrative grievance challenging the way the work bonus day credits are administered. After exhausting their administrative remedies, each1 applicant filed for postconviction relief. See Iowa Code § 663A.2(6). The district court denied them relief. Each applicant then appealed to this court. Because the issues in each case are the same, we ordered the three separate appeals consolidated.

III. Whether the Way the Reformatory Calculates Work Bonus Day Credits Violates Iowa Code Section 903A. 2.

Iowa Code section 903A.2 allows an inmate to reduce the inmate’s sentence in two ways: through good conduct time credits and through work bonus day credits. Specifically, the statute pertinently provides:

Each inmate of an institution under the Iowa department of corrections, is eligible for a reduction of sentence of one day for each day of good conduct of the inmate while committed to one of the department’s institutions. In addition to the sentence reduction of one day for each day of good conduct, each inmate is eligible for an additional reduction of sentence of up to five days a month if the inmate participates satisfactorily in employment in the institution....

Iowa Code § 903A.2 (emphasis added).

As they did in the district court, the applicants challenge the way the reformatory calculates work bonus day credits for purposes of section 903A.2.

Section 903A.2 authorizes a day-for-day reduction in an inmate’s sentence for good conduct. That means an inmate earns an extra day reduction in sentence for each day the inmate serves. The net effect of the credit is that the sentence is cut in half.

According to the reformatory’s method of computation, an inmate is given all of the good conduct day-for-day reduction against the entire sentence immediately upon the inmate’s commitment. This results in a projected reduction of sentence rather than an actual reduction. The computation produces what the reformatory calls a projected discharge date (PDD), which forecasts the actual time to be served. The calculation is based on the assumption that the inmate will serve the entire projected sentence.

Because the PDD is calculated before an inmate has completed even one day of the actual sentence, the PDD is subject to change. For example, loss of good conduct time because of a rule infraction can extend the PDD. But logically the loss of good conduct time must be computed by taking into account the day-for-day credit for each day served. For example, a loss of sixteen days of good conduct time extends the PDD or the . actual time to be served by eight rather than sixteen days. The sixteen days is like an additional sentence that must be reduced by the day-for-day credit the inmate receives upon com *30 mitment. In this example the day-for-day credit is eight days.

According to the State, the following example shows how the reformatory’s method of calculation works:

Length of sentence (2 years X 365 days) 730 days
Less maximum good conduct time credit available 365 days
Initial PDD 365 days
Loss of good conduct time for rule infraction 16 days
Less maximum good conduct time day-for-day credit available because of increase in confinement 8 days
Total increase to PDD 8 days
Add initial PDD 365 days
New PDD 373 days

As we said, work bonus day credits also reduce an inmate’s sentence. These credits are earned if the inmate “participates satisfactorily in employment in the institution.” Iowa Code § 903A.2.

Under the reformatory’s method, a calculation of work bonus day credits rests on the same logic that applies in calculating the loss of good conduct time. Like the latter calculation, the calculation of work bonus day credits must take into account the day-for-day credit originally given the inmate at the time of commitment. Again, this is because the day-for-day credit was projected on the assumption the inmate would serve the entire projected sentence.

Once work bonus day credits are earned, the inmate will not be serving the entire projected sentence and so will not be earning all of the day-for-day credits originally projected. The PDD must therefore be adjusted to reflect work bonus day credits and the reduction in day-for-day credits.

Unless the reduction in day-for-day credits is made, the inmate would receive a windfall: a double reduction in sentence. This double reduction would result from (1) the original day-for-day credit given at commitment and (2) a day-for-day credit given the inmate for time not served. Logically, then, because the original day-for-day credits reduced the sentence by one-half, the work bonus day credits must likewise be reduced by one-half.

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Related

State v. Orte
540 N.W.2d 435 (Supreme Court of Iowa, 1995)

Cite This Page — Counsel Stack

Bluebook (online)
480 N.W.2d 28, 1992 Iowa Sup. LEXIS 20, 1992 WL 6979, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bradham-v-state-iowa-1992.