State of West Virginia ex rel. Scott Phalen v. Craig Roberts

CourtWest Virginia Supreme Court
DecidedJune 16, 2021
Docket20-1023
StatusSeparate

This text of State of West Virginia ex rel. Scott Phalen v. Craig Roberts (State of West Virginia ex rel. Scott Phalen v. Craig Roberts) is published on Counsel Stack Legal Research, covering West Virginia Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of West Virginia ex rel. Scott Phalen v. Craig Roberts, (W. Va. 2021).

Opinion

FILED June 16, 2021 released at 3:00 p.m. EDYTHE NASH GAISER, CLERK No. 20-1023, State of West Virginia ex rel. Scott Phalen v. Craig Roberts SUPREME COURT OF APPEALS OF WEST VIRGINIA

Armstead, Justice, dissenting, joined by Chief Justice Jenkins:

It is unfortunate that, due to a mistake or clerical error, the Petitioner in this

case was erroneously released on parole and subsequently reincarcerated due to such error.

Nevertheless, based upon my review of applicable law and the policies promulgated by the

West Virginia Division of Corrections and Rehabilitation (DCR), I do not believe that

inmates, such as Petitioner, who are incarcerated for violating the conditions of their

extended supervised release, are eligible for parole nor are they entitled to receive

commutation from their sentences for good time served. Therefore, I respectfully dissent

from the majority’s decision.

Petitioner pled guilty to one count of first-degree sexual abuse and, in 2012,

was sentenced to one to five years in prison followed by fifteen years of extended

supervised release. 1 Pursuant to West Virginia Code § 62-12-26(a), the circuit court had

1 Petitioner’s term of imprisonment was imposed pursuant to West Virginia Code § 61-8B-7 (2006). Supervised release is governed by West Virginia Code § 62-12-26(a), which provides in pertinent part, as follows:

Notwithstanding any other provision of this code to the contrary, any defendant convicted [of] … a felony violation of the provisions of § 61-8B-1 et seq., … of this code shall, as part of the sentence imposed at final disposition, be required to serve, in addition to any other penalty or condition imposed by the court, a period of supervised release of up to 50 years: Provided, That the period of supervised release imposed by the court pursuant to this section … shall be no less than 10 years … And Provided further, That pursuant to the provisions of subsections (a) and (h) of this section, a court may modify, 1 no discretion in whether to impose a term of supervised release. After discharging his

prison sentence, Petitioner began the period of his supervised release. 2 Less than six

months after being discharged from prison, Petitioner violated his extended supervised

release. Accordingly, his term of supervised release was revoked, and he was remanded to

serve five years in prison. After discharging the five-year sentence, Petitioner was released

to complete his extended supervised release. Approximately two months later, he was once

again charged with violating his extended supervised release. He was then placed in the

custody of the DCR for ten years for this second violation. 3 Petitioner was improvidently

released on parole due to a “clerical error” for this violation on June 29, 2020.

DCR conducted a review of good time and parole eligibility and, as a result,

issued Policy Directive Number 151.06 on or about November 23, 2020. Policy Directive

151.06 established that certain inmates, including inmates who were incarcerated “pursuant

to revocation of extended supervision for sex offenders/child abusers,” were not entitled to

terminate, or revoke any term of supervised release imposed pursuant to this subsection.

W. Va. Code § 62-12-26(a). As the majority opinion observes, W. Va. Code § 62-12-26 has been amended since the time the Petitioner was sentenced for the underlying crime. Though I disagree with the majority’s understanding of this statute, I agree that the amendments are not relevant to Petitioner’s case. Accordingly, and like the majority, I cite to the 2020 version of the statute, which is now in effect.

2 Pursuant to West Virginia Code § 62-12-26(d), supervised release begins “upon the expiration of any period of probation, the expiration of any sentence of incarceration or the expiration of any period of parole supervision imposed or required of the person so convicted, whichever expires later.”

3 DCR contends that Petitioner did not commit a new crime. 2 “receive day-for-day good time for incarceration.” Petitioner was deemed to have been

released due to a clerical error or mistake and was arrested and incarcerated at South

Central Regional Jail. DCR argues, and I agree, that Policy Directive 151.06 was required

to bring DCR’s analysis of offender incarcerations in line with legislative enactments.

Parole Eligibility

An inmate’s eligibility for parole is outlined in West Virginia Code § 62-12-

13. See W. Va. Code § 62-12-13(b)(2021). 4 Of particular importance to the instant case

is the requirement that, in order to be released on parole, an inmate must have “served the

minimum term of his or her indeterminate sentence or has served one fourth of his or her

definite term sentence, as the case may be[.]” W. Va. Code § 62-12-13(b)(1)(A) (emphasis

added). In this case, the majority simply finds that Petitioner is eligible for parole during

his term of extended supervised release, because he is an inmate and has served one fourth

of his definite term of his original term of incarceration for the underlying crime. But the

analysis of W. Va. Code § 62-12-13(b)(1)(A) does not stop there. I believe that the

majority’s conclusion does not take into consideration the fact that this statute is written in

the context of the imposition of the original sentence and that the Petitioner, while on

4 As the majority opinion observes, West Virginia Code § 62-12-13 has been amended numerous times since 2012, when Petitioner was sentenced for the underlying offense. Though I disagree with the majority’s understanding of this statute, I agree that the amendments are not relevant to Petitioner’s case. Accordingly, and like the majority, I cite to the 2020 version of the statute, which is now in effect. 3 supervised release and extended supervised release, was serving a sanction, not a sentence,

as that term is used in W. Va. Code § 62-12-13(b)(1)(A).

This Court has previously described a sentence as “[t]he judgment formally

pronounced by the court or judge upon the defendant after his conviction … usually in the

form of … incarceration, or probation.” State ex rel. Goff v. Merrifield, 191 W. Va. 473,

477, 446 S.E.2d 695, 699 (1994). In the instant case, Petitioner was sentenced in 2012 to

one to five years in prison followed by fifteen years of supervised release for his conviction

of first-degree sexual abuse. At the time of his re-incarceration, he had discharged his

original sentence and was no longer subject to the sentence for his crime. He then began

serving his term of supervised release and then “extended supervised release.” We know

this because Petitioner’s period of extended supervised release could only begin “upon the

expiration of any period of probation, the expiration of any sentence of incarceration or the

expiration of any period of parole supervision imposed or required of the person so

convicted, whichever expires later.” W. Va. Code § 62-12-26(d). This Court has

previously described incarceration due to a violation of terms and conditions of extended

supervised release as a “sanction.” See Syllabus Point 7, State v. Hargus, 232 W. Va. 735,

753 S.E.2d 893 (2013). Therefore, because Petitioner had discharged the sentence for his

crime, his reincarceration was clearly a sanction for failing to comply with the terms and

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State of West Virginia ex rel. Scott Phalen v. Craig Roberts, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-west-virginia-ex-rel-scott-phalen-v-craig-roberts-wva-2021.