James William Taylor v. Tennessee Department of Correction
M2016-01350-COA-R3-CV
| Tenn. Ct. App. | Mar 13, 2017Background
- James William Taylor, serving multiple consecutive sentences including one life sentence with release eligibility after 30 years, filed a declaratory-judgment action challenging TDOC’s calculation of his release eligibility and claiming entitlement to custodial parole and safety-valve consideration.
- Original sentences (1988): life for first-degree murder (30 years release eligibility under the law then), two consecutive 15-year terms (each at 35% service), plus several shorter sentences later completed. TDOC applied credits and calculated an overall release-eligibility date.
- TDOC applied 3,767 days of Prisoner Sentence Reduction Credits to reduce the computed release-eligibility date to January 25, 2018.
- Taylor argued his sentence is a determinate sentence under Tenn. Code Ann. § 40-35-211 (pre-1982 law application) entitling him to custodial parole (Howell claim) and he argued safety-valve eligibility. He also raised an ex post facto challenge.
- Respondents moved for summary judgment supported by an affidavit from the Director of Sentence Management Services; the trial court found no genuine factual disputes, ruled TDOC calculated sentences correctly under the Tennessee Criminal Reform Act of 1982, denied custodial parole and safety-valve relief, and dismissed the petition. This appeal followed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether TDOC miscalculated Taylor’s release-eligibility date | Taylor: calculation is incorrect; he is owed additional credits and earlier eligibility | TDOC: calculations and application of credits are correct under applicable law | Affirmed: TDOC calculation correct; no genuine factual dispute |
| Whether Taylor has a determinate sentence entitling him to custodial parole (Howell) | Taylor: sentence is determinate under pre-1982 law so Howell custodial parole applies | Respondents: Howell applies only to determinate sentences before 1982; Taylor’s sentences are governed by the 1982 Reform Act and are not eligible | Held: Howell does not apply; custodial parole unavailable |
| Whether Taylor qualifies for safety-valve release | Taylor: asserts entitlement to safety-valve consideration | Respondents: safety-valve ineligible because governor excluded homicide convictions | Held: Not eligible for safety-valve release |
| Whether application of the controlling statutes violated the Ex Post Facto Clause | Taylor: change in law penalizes him retroactively | Respondents: sentences were calculated in accordance with the law in effect at time of offenses; no increased punishment | Held: No ex post facto violation; calculation follows applicable law |
Key Cases Cited
- Howell v. State, 569 S.W.2d 428 (Tenn. 1978) (custodial parole concept under pre-1982 determinate sentencing)
- State v. Pearson, 858 S.W.2d 879 (Tenn. 1993) (ex post facto inquiry focuses on whether law increases punishment)
- Greenholtz v. Inmates of Neb. Penal & Corr. Complex, 442 U.S. 1 (1979) (no constitutional right to release before sentence expiration)
- Shorts v. Bartholomew, 278 S.W.3d 268 (Tenn. 2009) (discussion of responsibilities for calculating and enforcing sentence terms)