State of West Virginia v. Edwin Mack Taylor

Summary

The Supreme Court of Appeals of West Virginia affirmed the denial of Edwin Taylor’s request for additional credit for time served. The court held that constitutional principles requiring credit for pretrial confinement did not require credit toward Taylor’s felony sentence for time spent incarcerated on separate, unrelated charges that were dismissed under a universal plea agreement. Taylor was constitutionally entitled to credit for the twelve days served on the offense for which he was convicted.

Holdings

1. The Double Jeopardy and Equal Protection Clauses of the West Virginia Constitution do not constitutionally require credit against a sentence for time spent incarcerated on separate, factually and temporally unrelated charges merely because those charges were dismissed as part of the same universal plea agreement.
2. West Virginia Code § 61-11-24 does not require credit against a sentence for confinement on separate, unrelated offenses; the twelve days spent incarcerated awaiting trial and conviction on the offense of conviction were properly credited.
3. The circuit court did not abuse its discretion or otherwise err in denying Taylor's Rule 35 motion for additional time-served credit.

Questions Presented

1. Whether the Double Jeopardy and Equal Protection Clauses of the West Virginia Constitution required credit against Taylor's felony sentence for time he spent incarcerated on separate March 2017 charges that were dismissed as part of the same universal plea agreement.
2. Whether West Virginia Code § 61-11-24 required credit for confinement on unrelated offenses resolved in the same plea agreement.
3. Whether the circuit court abused its discretion or otherwise erred in denying Taylor's Rule 35 motion for additional credit for time served.

Disposition

affirmed