Massey v. Louisiana Dept. of Safety & Corrections
Annotate this CaseThe issue on appeal in this case was whether defendant Paul Massey was eligible to receive “good time” credits when the law changed after the offenses were committed, eliminating Massey’s eligibility to earn early release. In 2006, the Legislature amended the statute that gave inmates the capacity to earn early release from their prison sentence in exchange for good behavior and the performance of work or self-improvement activities. The amendment significantly narrowed the class of inmates qualified to receive good time credits, excluding from eligibility, as pertinent here, those convicted of felony carnal knowledge of a juvenile or molestation of a juvenile. Massey committed both felony carnal knowledge of a juvenile and attempted molestation of a juvenile in 1994. His victims, however, did not report his crimes to the authorities until 2004, and a jury did not convict Massey of these offenses until 2007. The Supreme Court was asked to decide which version of the good time statute applied to Massey - the law in effect at the time he committed his crimes or the law in effect at the time of his conviction, which would have denied him early release regardless of his demonstrated good behavior. Because the rescission of good time eligibility creates a significant risk of prolonging his incarceration and increases the severity of Massey’s sentence by altering the terms and conditions under which he must serve his penalty, the Supreme Court found application of the amended law would violate the ex post facto clauses of the United States and Louisiana Constitutions. Applying the law in effect at the time the offenses were committed, the Court found Massey was eligible to receive good time credits and is entitled to have his time recomputed under the statute before it was amended.
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