James Dunn v. Missouri Department of Corrections

CourtMissouri Court of Appeals
DecidedMarch 22, 2022
DocketWD84515
StatusPublished

This text of James Dunn v. Missouri Department of Corrections (James Dunn v. Missouri Department of Corrections) is published on Counsel Stack Legal Research, covering Missouri Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
James Dunn v. Missouri Department of Corrections, (Mo. Ct. App. 2022).

Opinion

IN THE MISSOURI COURT OF APPEALS WESTERN DISTRICT JAMES DUNN, ) Appellant, ) ) v. ) WD84515 ) MISSOURI DEPARTMENT OF ) FILED: March 22, 2022 CORRECTIONS, ) Respondent. ) Appeal from the Circuit Court of Cole County The Honorable Daniel R. Green, Judge Before Division Two: Alok Ahuja, P.J., and Edward R. Ardini, Jr., and Janet Sutton, JJ.

James Dunn is currently incarcerated based on sentences he received in 1997

for second-degree murder and armed criminal action. Dunn filed a petition for

declaratory judgment against the Department of Corrections in the Circuit Court of

Cole County. Dunn claimed that the Board of Probation and Parole had incorrectly

recalculated his parole eligibility date. Dunn contended that the Board’s

recalculation was based on new Board regulations which were not in effect at the

time he was sentenced, which changed the minimum prison term on Dunn’s armed

criminal action conviction. Dunn claimed that the Board’s new parole eligibility

calculation conflicted with the governing statutes, and violated multiple

constitutional provisions. The circuit court granted the Department of Corrections’

motion for judgment on the pleadings, and Dunn appeals. We affirm. Factual Background

In June 1997, Dunn was convicted in the Circuit Court of St. Louis County of

second-degree murder, in violation of § 565.021,1 and armed criminal action, in

violation of § 571.015. The charges arose from Dunn’s fatal shooting of Larry

Pearson in Maplewood on March 31, 1996. Dunn was convicted following a jury

trial. The circuit court sentenced him to life imprisonment for both the murder and

armed criminal action convictions, with the sentences ordered to run consecutively.

Beginning in 1979, § 571.015.1 has provided that, in connection with a first

conviction of armed criminal action, “[n]o person convicted under this subsection

shall be eligible for parole . . . for a period of three calendar years.”

On August 1, 2019, Dunn received a notice from the Board of Probation and

Parole that he was scheduled for a parole hearing on October 10, 2019. Dunn

alleged that the Board scheduled the October 2019 parole hearing based on its view

that §§ 558.019.3 and .4(1) required him to serve 85% of his sentence for second-

degree murder (with his life sentence calculated at thirty years), and that he was

required to serve an additional three years on his armed criminal action conviction

by operation of § 571.015.1.

On October 15, 2019, Dunn received another notice from the Board,

informing him that his parole hearing had been rescheduled to June 2036. Dunn

requested an explanation for the seventeen-year delay of his initial parole hearing.

1 Unless otherwise indicated, statutory citations refer to the 1994 edition of the Revised Statutes of Missouri.

2 The Board explained that Dunn’s parole eligibility on his armed criminal action

conviction was governed by the “15 year rule” in the Board’s “Procedures Governing

the Granting of Parole and Conditional Release” (the “Blue Book”).2 Section 19(E)

of the Blue Book specifies that “[o]ffenders serving life . . . sentences . . . may not be

eligible for parole until a minimum of 15 years has been served, except where

statute requires more time to be served.” The Board also informed Dunn that,

although it previously scheduled offenders for an initial parole hearing two years

prior to the conclusion of their minimum prison terms, the Board had adopted a new

rule effective September 1, 2019, under which it was now scheduling offenders for

an initial parole hearing four months prior to their earliest parole eligibility date.

Dunn filed a petition for declaratory judgment against the Department of

Corrections in the Circuit Court of Cole County on September 1, 2020. Dunn

argued that the Board’s recalculation of his minimum parole eligibility date was in

conflict with various Missouri statutes and regulations. Dunn also alleged that the

Board’s determination that he was required to serve a minimum of fifteen years on

his life sentence for armed criminal action conflicted not only with the governing

statutes, but also with one of the Board’s own pre-2008 regulations. Dunn

contended that the Board’s retroactive application of its newer regulations

constituted an unconstitutional ex post facto law. He also alleged that the

redetermination of his parole eligibility date violated separation of powers

2 The current version of the Blue Book, revised on January 1, 2017, is available at https://doc.mo.gov/sites/doc/files/2018-01/Blue-Book.pdf.

3 principles, as well as Dunn’s constitutional rights to due process of law and to the

equal protection of the laws.

Both Dunn and the Department filed motions for judgment on the pleadings.

The circuit court granted the Department’s motion for judgment on the pleadings,

and denied Dunn declaratory relief. Following the denial of his motion to set aside

the judgment, Dunn filed the current appeal.

Standard of Review

This Court reviews a circuit court’s ruling on a motion for judgment on the

pleadings de novo. Woods v. Mo. Dep’t of Corr., 595 S.W.3d 504, 505 (Mo. 2020)

(citing Mo. Mun. League v. State, 489 S.W.3d 765, 767 (Mo. 2016)). “‘[A] motion for

judgment on the pleadings should be sustained if, from the face of the pleadings, the

moving party is entitled to judgment as a matter of law.’” Id. (quoting Madison

Block Pharmacy, Inc. v. U.S. Fid. & Guar. Co., 620 S.W.2d 343, 345 (Mo. 1981)).

Discussion

On appeal, Dunn does not challenge the Board’s determination that he must

serve 85% of his life sentence for second-degree murder, with the life sentence

treated as a thirty-year term of imprisonment. Dunn also does not challenge the

Board’s conclusion that, because his sentences were ordered to run consecutively, he

must serve any minimum prison term on his armed criminal action conviction in

addition to the minimum prison term for his second-degree murder conviction,

before he will become parole-eligible. Instead, Dunn challenges only the Board’s

conclusion that, before Dunn is eligible for parole, he must serve fifteen years on his

4 life sentence for armed criminal action. Dunn contends that – at least under the

law as it existed at the time of his underlying offense, conviction, and sentencing –

he is only required to serve three years before being eligible for parole on his armed

criminal action conviction.

Although Dunn contends that the Board’s recalculation of his parole

eligibility date violates multiple constitutional provisions, statutes, and regulations,

all of his claims rely on his interpretation of three legal authorities: § 217.690.4;

§ 571.015.1; and the Board regulation which appeared at 14 C.S.R. 80-2.010(4)(A)(1)

prior to 2008. None of these authorities ever provided, however, that Dunn would

be eligible for parole on his armed criminal action conviction after serving only

three years of his life sentence.

At the time of Dunn’s offense and conviction, § 217.690.4 specified the

manner in which parole eligibility was determined for offenders serving consecutive

sentences. Section 217.690.4 provided:

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Bluebook (online)
James Dunn v. Missouri Department of Corrections, Counsel Stack Legal Research, https://law.counselstack.com/opinion/james-dunn-v-missouri-department-of-corrections-moctapp-2022.