Snyder v. Andrews

708 A.2d 237, 1998 Del. LEXIS 117, 1998 WL 149396
CourtSupreme Court of Delaware
DecidedMarch 24, 1998
Docket482, 1996
StatusPublished
Cited by25 cases

This text of 708 A.2d 237 (Snyder v. Andrews) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Snyder v. Andrews, 708 A.2d 237, 1998 Del. LEXIS 117, 1998 WL 149396 (Del. 1998).

Opinion

HARTNETT, Justice:

We consider the issue of how good time credits are to be deducted from the period of incarceration for an inmate who is serving two prison terms, one for crimes committed before the enactment of the Truth-in-Sen-teneing Act of 1989 1 (“the Act”), and the other for crimes occurring after the new law became effective. The Act applies to sentences for crimes committed after June 29, 1990 and, among other things, it eliminated parole. 2 The Act also significantly reduces the amount of good time credits available to diminish an inmate’s period of incarceration. 3 As will be seen, the Act does not address how good time credits are deducted if there are multiple sentences, some imposed before and some after the effective date of the Act.

Nature of Proceedings

While incarcerated, Thomas Andrews, the appellee, sought a writ of mandamus in the Superior Court seeking to compel Warden Robert F. Snyder of the Department of Correction (“Department”) to reallocate the good time credits he has already earned while in custody. Andrews is serving multiple sentences, some imposed for crimes committed prior to the effective date of the Truth-in-Sentencing Act and some imposed for crimes committed after the Act became effective. The Superior Court agreed with Andrews and issued a writ of mandamus directing Warden Snyder to reallocate the good time credits. The primary issue presented in this appeal is whether Andrews is entitled (as he claims) to have some of the good time credits he has earned while incarcerated credited now to the sentences he received on crimes committed after the effective date of the Act or whether his good time credits should not be credited until the end of all the sentences he is now serving. Unlike the Superior Court, we find that the Department is correct in its assertion that Andrews is not entitled to any good time being credited against his various sentences until the end of his total term of incarceration.

*239 We also find that the method used by the Department to credit Andrews with good time does not violate any ex post facto right and we, therefore, REVERSE.

The Facts

The facts are not in dispute. On June 26, 1991, Andrews was sentenced in the Superior Court to two consecutive seven-year prison terms for two separate charges of violating probation on sentences imposed for crimes that occurred prior to June 29, 1990, the effective date of the Truth-in-Sentencing Act. The June 1991 sentences were imposed in accordance with the statutory provisions that existed prior to the enactment of the Act and carry- the possibility of parole. Subsequently, on October 11, 1991, Andrews was sentenced in the Superior Court to two consecutive two-year terms of imprisonment for two new crimes that occurred after June 29,1990. The later October 1991 sentences were imposed after the Act became effective and are not subject to parole eligibility.

Good time credits on a sentence imposed after the Act are earned at a significantly lesser rate than under a sentence imposed prior to the Act. Where there are multiple sentences, some based on crimes occurring before the Act and some based on crimes occurring after the Act, the Department first computes the estimated good time credits based on the total of the inmate’s sentences imposed prior to the Act and then separately computes the estimated good time credits based on the total of the inmate’s sentences imposed after the Act. The sum total of the inmate’s estimated good time under both computations is then conditionally subtracted from the total prison terms that the inmate is serving. The Department used this method to calculate and credit the good time that Andrews has already accumulated. Andrews concedes that the Department properly calculated all of the good time to which he is conditionally entitled. His dispute relates solely to the Department crediting his good time to the end of his total prison terms.

The dispute over the Department’s method of crediting good time arises from 11 Del.C. § 4216(a), which was adopted in 1989 as part of the Truth in Sentencing Act. This section attempted to provide for the transition from the prior sentencing provisions to the new provisions. 11 Del.C. § 4216(a) provides:

Where an inmate is serving a sentence to Level V (incarceration) imposed not under the Truth in Sentencing Act of 1989 and receives a subsequent sentence to Level V under the provisions of the Truth in Sentencing Act, serving of the earlier sentence shall be suspended and the inmate shall serve the new Level V sentence until it is completed and then resume serving the original sentence.

Section 4216(a) thus requires Andrews to first serve the sentences imposed after the Act became effective before resinning service of his prior sentences. Accordingly, the Department interrupted the awarding of good time on Andrews’ fourteen-year prison term that had been imposed for crimes committed prior to the Act while he served his four-year term imposed for crimes committed after the Act became effective.

The Superior Court Proceedings

Andrews filed a pro se petition for a writ of mandamus in the Superior Court alleging that the Department acted incorrectly when it deducted from his total eighteen-year term of incarceration the good time credits that he has earned while serving the four-year prison term imposed after the Truth-in-Sentencing Act had been enacted. Andrews asserted that he is entitled to have now deducted from his four-year prison sentence that was imposed after the Act was enacted the good time credits that he already has earned while serving that sentence. The net result to Andrews, if the good time he has earned is applied to reduce his four-year after Truth-in-Sentencing prison term rather than his eighteen-year aggregated term, would be a reduction on his four-year after Truth-in-Sentencing sentence and concomitant earlier return to serving the sentence imposed prior to the Act.

If this is done, Andrews will accrue good time at a rate greater than on the sentence imposed after the Act. If he is correct, his parole eligibility date under the sentence imposed before Truth-in-Sentencing will be nearly five and one-half months earlier than *240 it will be using the Department’s method of crediting good time. He, therefore, claims he would be released 5% months earlier at the end of all of his sentences. 4

The Superior Court concluded that the language of the Truth-in-Sentencing Aet imposed a duty upon the Department to now credit Andrews with the good time credits he has acquired while serving his post-Act sentence so that he will complete that sentence sooner and will then earlier return to serving the sentences imposed before the Act became effective. Accordingly, the Superior Court issued a writ of mandamus to Warden Snyder directing him to credit the good time as Andrews requested. This appeal ensued.

After reviewing the briefs, the Court appointed Bernard J. O’Donnell, Esquire, to file a brief as amicus curiae in support of Andrews’ position. 5

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Bluebook (online)
708 A.2d 237, 1998 Del. LEXIS 117, 1998 WL 149396, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snyder-v-andrews-del-1998.