In re Pers. Restraint of Talley
Annotate this CaseThe primary issue presented in this case was whether former RCW 9.92.151 (2004) or the equal protection clause of the United States Constitution requires a county jail to provide opportunities for an inmate who is yet to be sentenced to earn credit toward early release, also known as "good-time" credit. Petitioner, Teddy Talley argued that the Skamania County Jail and the Department of Corrections (Department) violated the former RCW 9.92.151(1) and the Constitution by not providing opportunities for him to earn good-time credit before his criminal conviction. Skamania County argued that the statutory issue was not properly before the Supreme Court and that its program for earning good-time credit is constitutional. The Department argued that it may rely on a county’s jail-time certification when determining the appropriate amount of good-time credit to apply toward early release. Upon review, the Supreme Court held that the matter was properly before it, and that the former RCW 9.92.151 required a county jail to provide opportunities for a presentence inmate to earn good-time credit. The Court did not reach Defendant's constitutional argument. Because the Skamania County Jail policy conflicted with the former RCW 9.92.151, the Court calculated that Defendant should have received an earned early-release credit at the statutory maximum rate of 15 percent.
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