Johnson v. Virginia Parole Board

65 Va. Cir. 149, 2004 Va. Cir. LEXIS 142
CourtFairfax County Circuit Court
DecidedJune 21, 2004
DocketCase No. (Law) 213322
StatusPublished

This text of 65 Va. Cir. 149 (Johnson v. Virginia Parole Board) is published on Counsel Stack Legal Research, covering Fairfax County Circuit Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Johnson v. Virginia Parole Board, 65 Va. Cir. 149, 2004 Va. Cir. LEXIS 142 (Va. Super. Ct. 2004).

Opinion

By Judge Robert W. Wooldridge, Jr.

This matter is before the Court on Respondents’ Motion to Dismiss the Petition for Writ of Habeas Corpus filed by Petitioner, Henry Johnson, n. Johnson contends that he is being wrongfully detained at the Sussex II State Prison because of Respondent’s failure to provide Petitioner his parole hearings on two occasions in accordance with Code of Virginia § 53.1-136 and § 19.2-308.1. Johnson further asserts that he is being wrongfully detained because Respondent does not have discretion to reinstate previously earned Code ofVirginia § 53.1-199 “good conduct allowance,” following Johnson’s subsequent parole violation. The Court has considered the Petition, Respondent’s Motion to Dismiss, Johnson’s Motion to Deny the Motion to Dismiss, and the relevant cases and statutes. For the reasons set forth in this opinion letter, the Motion to Dismiss is granted and the Petition for Writ of Habeas Corpus is dismissed.

I. Background

On April 11, 1986, Johnson was found guilty of rape in violation of Va. Code § 18.2-61 and sentenced to twenty years in prison. Johnson was released from prison on mandatory parole on June 14, 2000 after serving approximately 14.5 years of his twenty year sentence; Johnson was arrested [150]*150for trespass in Raleigh, N.C., and, on February 2,2001, he was found guilty of second degree trespassing and sentenced to eight days. Subsequently, Johnson was extradited to Virginia where he was received at the Powhatan Reception and Classification Center on February 13,2001.

At a subsequent parole violation hearing, Johnson admitted to having violated parole conditions one, six, and ten. On April 23, 2001, the Virginia Parole Board revoked Johnson’s parole. Pursuant to Va. Code §§ 53.1-159 and 53.1-165 and Parole Board Policy, the Parole Board also authorized that Johnson serve the full portion of the term imposed by the sentencing court that had not expired when he was released on mandatory parole; that time equaled four years, eleven months, and one day plus the six months and twenty-five days time left to serve from parole. Johnson’s next parole hearing was not until May 16, 2003. On May 27, 2003, the Parole Board voted not to grant parole to Johnson.

II. Johnson’s Claims

Johnson contends that he is being held illegally and is entitled to mandatory release: (1) as a result of not having received discretionary parole hearings pursuant to Va. Code § 53.1-136; and, (2) as a result of the Parole Board’s unauthorized revocation of good conduct allowance previously earned.

In response, Respondent argues that Johnson’s claim is not sufficient to show that he was denied life, liberty, or due process. First, Respondent argues that, under the Fourteenth Amendment there is no constitutional right of a convicted person to be conditionally released before expiration of a valid sentence. Hill v. Jackson, 64 F.3d 163 (4th Cir. 1995). Respondent argues that petitioner has introduced no evidence of prejudice resulting from an unreasonable error and the Parole Board is considering granting Petitioner additional hearings to make up for those previously missed. Second, Respondent argues that Johnson’s claim that he is entitled to mandatory release is procedurally barred under Virginia Rules of Civil Procedure. Va. Code § 8.01-654(A)(2) (2000).

Johnson’s Response argues that the Parole Board’s delay in granting a parole hearing prejudiced Petitioner’s consideration of release because there was “a likelihood” that, if considered promptly, he would have been released.

[151]*151III. Analysis

A. The Function of Writs of Habeas Corpus

The purpose and scope of the writ of habeas corpus is to test the legality of the prisoner’s detention. Virginia Parole Bd. v. Wilkins, 255 Va. 419, 420, 498 S.E.2d 695 696 (1998). The writ of habeas corpus cannot be issued to correct a mere error, but must be issued to discharge a prisoner who is being unlawfully detained. Smyth v. Midgett, 199 Va. 727, 101 S.E.2d 575 (1958).

B. Rule Against Successive Petitions

Claims set forth in a habeas petition may be procedurally barred if they were not timely raised in any prior habeas petition filed by the same petitioner. Va. Code § 8.01-654. In other words, when a habeas petition is filed, the prisoner must include all claims arising out of facts that are known to the prisoner at that time. Dorsey v. Angelone, 261 Va. 601, 544 S.E.2d 350 (2001). In Dorsey, the petitioner had filed a prior habeas petition that was voluntarily withdrawn. Id. at 604. The prior petition only challenged the computation of good time credits relating to his March 1987 felony sentences. In the second petition, the prisoner claimed seven new challenges to his detention. The petitioner was deemed to have had knowledge of the facts giving rise to the claims in the second petition at the time the first petition was filed, and the Court held the new claims in the Second petition were procedurally barred by Va. Code § 8.01-654(B)(2). Id.

C. Merits of Johnson’s Claims

1. The Parole Hearings Claim

There is no constitutional right of a prisoner to be conditionally released before the expiration of a valid sentence. Greenholtz v. Nebraska Penal Inmates, 442 U.S. 1, 7, 60 L. Ed. 2d 668, 99 S. Ct. 2100 (1979).

In Hill v. Jackson, several inmates brought actions to challenge the constitutionality of a Virginia parole review policy, which provides for the deferral of parole review hearings for up to three years for certain classes of inmates. 64 F.3d 163 (1995). In discussing the inmates’ claim that the Parole Board’s 1993 parole review deferral policy deprived them of their liberty without due process in violation of the Fourteenth Amendment, the Fourth Circuit Court of Appeals noted that, “although the inmates may have some interest in parole consideration generally, it is clear that there is no ‘protected [152]*152liberty interest in the procedures themselves, only in the subject matter to which they are directed’.” Id. at 170 (quoting Ewell v. Murray, 11 F.3d 482, 488 (4th Cir. 1993)). The Fourth Circuit went on to hold that “because the inmates’ ‘right’ to annual parole review here is a procedural function of Virginia’s parole scheme rather than a substantive right unto itself, the Constitution does not afford that ‘right’ any protection under the Due Process Clause.” Id. at 171.

In Virginia Parole Board v. Wilkins, Wilkins had petitioned for writ of habeas corpus after the Parole Board denied him discretionary parole and deferred for two years his next parole review. 255 Va.

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Related

Dorsey v. Angelone
544 S.E.2d 350 (Supreme Court of Virginia, 2001)
Virginia Parole Board v. Wilkins
498 S.E.2d 695 (Supreme Court of Virginia, 1998)
Hawks v. Cox
175 S.E.2d 271 (Supreme Court of Virginia, 1970)
Smyth v. Midgett
101 S.E.2d 575 (Supreme Court of Virginia, 1958)
Ewell v. Murray
11 F.3d 482 (Fourth Circuit, 1993)
Hill v. Jackson
64 F.3d 163 (Fourth Circuit, 1995)

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Bluebook (online)
65 Va. Cir. 149, 2004 Va. Cir. LEXIS 142, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-v-virginia-parole-board-vaccfairfax-2004.