Vermont v. Byam
Annotate this CaseDefendant Dale Byam appealed a trial court’s denial of his motion seeking credit against his sentence for time spent under pretrial conditions of release. Defendant argued on appeal to the Vermont Supreme Court there was a corollary to the Court's decisions in Vermont v. McPhee, Vermont v. Platt, and Vermont v. Kenvin, that would give him credit for days when he was subject to a twenty-four-hour curfew with exceptions, but when there was no guarantee that he was in fact compliant with the curfew. The Court declined to adopt defendant’s proposed rule and instead adopt a rule under which nonstatutory home detention with a condition-of-release curfew is never sufficiently akin to penal incarceration to justify credit. Although the Court's rationale was different than that applied by the trial court, the result was the same.
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