Mills v. Dep’t of Corr. Offender Info. Servs.
Annotate this CaseAppellant pleaded guilty to several offenses, including manufacturing methamphetamine while in possession of a firearm and being a first-degree persistent felony offender, and received a maximum sentence of twenty years’ imprisonment. Based on his convictions, the Department of Corrections classified Appellant as a violent offender, which required Appellant to serve a greater part of his sentence before reaching parole eligibility. Appellant sued the Department in circuit court to block the violent-offender classification’s application to him, arguing that his convictions were all non-violent drug offenses. The circuit court dismissed Appellant’s suit, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the Controlled Substances Act operates to enhance the conviction, not simply the sentence; and (2) the firearm-enhancement provision of the Act served to elevate Appellant’s conviction for manufacturing methaphetamine from a Class B to a Class A felony conviction, which qualified Appellant for classification as a violent offender.
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