Putnam v. Epps

Summary

The Mississippi Supreme Court held that a prisoner’s challenge to the Mississippi Department of Corrections’ calculation of earned time is properly brought through the administrative-review procedure, rather than as a motion for post-conviction relief. The court further held that venue was proper in the First Judicial District of Hinds County because the defendant, the MDOC commissioner, maintained offices there. The judgment was reversed and remanded for transfer from Yazoo County to Hinds County.

Holdings

1. A prisoner's challenge to the Mississippi Department of Corrections' earned-time calculation is not a motion for post-conviction relief; it is a claim cognizable under the administrative-review procedure in Mississippi Code sections 47-5-801 through 47-5-807.
2. Venue for Putnam's complaint was proper in the First Judicial District of Hinds County, where the MDOC commissioner's offices were located, rather than in Yazoo County.

Questions Presented

1. Whether Putnam's challenge to the Mississippi Department of Corrections' earned-time calculation was a post-conviction-relief motion or a complaint for judicial review under Mississippi Code sections 47-5-801 through 47-5-807.
2. Whether venue was proper in Yazoo County or instead in the First Judicial District of Hinds County.

Disposition

reversed_and_remanded