Summary
The Supreme Judicial Court of Massachusetts affirmed the denial of habeas corpus relief to a prisoner who claimed entitlement to good-time deductions and credits for a period during which he was serving a concurrent firearm sentence. The court held that good-time deductions and credits applied to the eligible armed robbery sentence only during its committed portion and could not be carried forward or applied retroactively after that portion was completed.
Topics
Practice areas
Questions Presented
- Whether a prisoner serving concurrent sentences may continue to receive statutory good-time deductions and earned good-time credits on an eligible sentence after completing the committed portion of that sentence while remaining incarcerated on a separate sentence that is ineligible for good-time deductions.
- Whether Reynolds was detained beyond the expiration of his armed robbery sentence.
Holdings
- Good-time deductions and earned good-time credits are applied to the eligible sentence being served and do not continue to accrue on that sentence after its committed portion has been completed while the prisoner remains in custody on a separate, ineligible sentence.
- Reynolds was not detained beyond the expiration of his sentence because he was not serving the armed robbery sentence during the period for which he sought additional good-time credit.
Key quotations
“Meanwhile, as it accrues, good time is applied to any eligible sentence being served — it is not held in reserve for application with the benefit of hindsight so as to obtain maximum over-all reduction in total incarcerated time.” (1009)
Factual background
Reynolds was serving a six-to-seven-year firearms sentence when he received a concurrent split sentence of six to ten years for armed robbery, with three years committed and the balance suspended on probation. Because of statutory good-time deductions and earned credits, he completed the committed portion of the armed robbery sentence on August 29, 1996, but remained incarcerated on the firearms sentence until his parole in March 1998. After his probation was revoked in 2001, he sought credit on the armed robbery sentence for the period from August 29, 1996, through his release on parole, arguing that he had been detained beyond the expiration of that sentence.
Procedural history
After violating probation on his armed robbery sentence, Reynolds was ordered to serve the balance of that sentence and received 203 days of credit for post-surrender custody. A Superior Court judge later denied his motion to correct the mittimus, in which he sought good-time deductions or credits for a period during which he remained incarcerated on a separate firearms sentence. The county court single justice denied habeas relief and reconsideration, and the Supreme Judicial Court affirmed.