Chandler v. Pallito
Annotate this CasePlaintiff Dennis Chandler appealed a superior court decision denying his claim for summary judgment, and granting the summary judgment motion filed by the Commissioner of the Vermont Department of Corrections. Plaintiff claimed that several statutes and policies enacted after his incarceration had the collective effect of retroactively increasing the length of his sentence and, as a result, violated the Ex Post Facto Clause of the U.S. Constitution. The Vermont Supreme Court affirmed, concluding that, because the statutes and policies did not retroactively alter or limit the Department’s discretion over plaintiff’s treatment programming and early release, their application did not result in a longer sentence than under the prior statutes and policies.
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