Smith v. State Board of Parole

683 P.2d 998, 297 Or. 184, 1984 Ore. LEXIS 1388
CourtOregon Supreme Court
DecidedMay 30, 1984
DocketCA A25158; SC 29740
StatusPublished
Cited by2 cases

This text of 683 P.2d 998 (Smith v. State Board of Parole) is published on Counsel Stack Legal Research, covering Oregon Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Smith v. State Board of Parole, 683 P.2d 998, 297 Or. 184, 1984 Ore. LEXIS 1388 (Or. 1984).

Opinion

PETERSON, C. J.

In 1979, the Oregon Legislature adopted an enhanced penalty statute which required an offender to serve a minimum term of imprisonment for the use or threatened use of a firearm during the commission of a felony. ORS 161.610(4) provides that work release or parole is not permitted “until the minimum term of imprisonment is served, less reductions of imprisonment for good time served * * *” (Emphasis added.) The petitioner was convicted of a crime involving the use of a firearm and was sentenced to a 20-year term of imprisonment with a five-year statutorily required minimum. The issue in this case is whether the Board of Parole was correct in its assumption that ORS 161.610 required that it set petitioner’s initial parole release date at not less than five years, with no reduction of the five-year minimum for “good time.” We conclude that the Board erred, reverse the Court of Appeals and remand the case to the Board of Parole for further proceedings consistent with this opinion.

I

Historically, when a person was sentenced to a term of imprisonment, the entire sentence was served before release. Reformers argued that fixed sentences shattered any hope of early release and embittered the prisoner against the correctional institution. They claimed that a rigid sentence structure was counterproductive to rehabilitation.

Starting with New York in 1817 and adopted by every state and the District of Columbia by 1916, “good time” laws were passed allowing prison administrators to reduce fixed sentences as a reward for a prisoner’s good behavior. See generally, Giardini, Goodtime - Placebo of Correction, Amer J Corr, March-Apr 1958, at 3ff. “Good time” statutes were a form of statutory commutation, subject only to verification by prison officials that the prisoner behaved well. Good time, once credited, functioned as an absolute reduction in a prisoner’s sentence. A prisoner’s release, with credit for good time earned, was unconditional, and the full sentence was deemed served.

Parole is a program in which an offender, after serving part of a sentence, is conditionally released under [187]*187supervision. The offender’s parole is contingent upon continued satisfactory behavior and compliance with stated conditions. The concept of parole was first advocated in the mid-nineteenth century and has become prevalent in the United States since the 1940’s. D. Dressier, Practice and Theory of Probation and Parole 44-61 (1959). Parole provides a transitional period of supervision to aid the parolee in readjusting to society and attempts to protect society from the potential recidivist. Id. at 61.

II

The Oregon statute concerning the calculation of and credit for “good time”1 is ORS 421.120, which provides in part:

“(1) Each inmate confined * * * upon any conviction in the penal or correctional institution, for any term other than life, and whose record of conduct shows that the inmate faithfully has observed the rules of the institution, shall be entitled to a deduction from the term of sentence to be computed as follows:
“(b) From the term of a sentence of more than one year, one day shall be deducted for every two days of such sentence actually served in the penal or correctional institution.
“(h) The Corrections Division shall develop * * * a uniform procedure for granting, retracting and restoring deductions allowed in paragraphs (a) to (g) of this subsection.”

As mandated by ORS 421.120(1)(h), the Corrections Division has promulgated rules designed to create a uniform procedure for granting, retracting and restoring good time. See generally OAR 291-100-005 to 291-100-060.

ORS 421.120(1) (b) seems to require that deductions for good time be credited after the good time has been earned. [188]*188However, as one commentator has noted, the constant earning and subsequent deduction of good time may result in an administrative nightmare.

“Good time may be credited automatically in a lump sum at the beginning of a prison sentence or credited month by month as it is earned. The latter method forces the prison to constantly recalculate the prisoner’s release dates. This recalculation, of course, is an enormous administrative burden. In large prison systems with vast inmate turnover and scarce resources, it is inconceivable that a thoughtful decision could be made each month as to whether an individual prisoner deserves to be awarded good time. Therefore, there is an inexorable tendency for statutory and meritorious good time to be awarded automatically. * * *
“The point is significant. Good time systems are necessarily bureaucratized. Time credits have become automatic; individual decisionmaking goes only to the question of forfeiture. * * *” (Footnotes omitted.) Jacobs, Sentencing by Prison Personnel: Good Time, 30 UCLA L Rev 217, 225 (1982).

The Corrections Division appears to follow this general approach. OAR 291-100-050(1) states that a work sheet will be prepared for every “new commitment” in an Oregon Corrections Division facility which will include, in addition to other sentence information, “[t]he amount of Statutory Good Time earned on the total sentence subtracted from the Maximum Date * * This rule suggests a practice under which anticipated statutory good time is calculated at or near the time of admission and subtracted from the maximum term of confinement under the sentence of the court.2

In the process of establishing a date for release on parole, the Board of Parole apparently recognizes the efficiency of noting good time deductions from the maximum [189]*189sentence at the outset. In the instant case the Board Action Form setting the 60-month imprisonment before parole lists petitioner Smith’s good time date as August 1, 1994, even though his 20-year sentence runs until April 1, 2001. By including this administrative data, the Board of Parole neither confers good time credit nor overrides the jurisdiction of the Corrections Division. It merely informs all concerned that if the inmate faithfully performs within the rules of the institution where he or she is incarcerated, he or she will be entitled to absolute release on the “good time” date.3

Ill

Petitioner pleaded guilty to first degree manslaughter and no contest to a charge of attempting to use a dangerous weapon. He was sentenced to 20 years on the manslaughter charge and five years on the attempt. The sentences were to run concurrently.

Because both crimes were committed with a firearm, the sentencing court ordered that petitioner serve a minimum of five years before he would be eligible for work release or parole. ORS 161.610(5)(a).

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Related

Watts v. Maass
746 P.2d 220 (Court of Appeals of Oregon, 1987)
Haffey v. Keeney
735 P.2d 16 (Court of Appeals of Oregon, 1987)

Cite This Page — Counsel Stack

Bluebook (online)
683 P.2d 998, 297 Or. 184, 1984 Ore. LEXIS 1388, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-state-board-of-parole-or-1984.