Jenkins v. Amsberry, 2:17-cv-00375

Petitioner Michael W. Jenkins was serving multiple consecutive indeterminate "matrix" sentences imposed in 1979–1980 and later received a consecutive 15‑month guidelines sentence for supplying contraband.
On March 5, 2013 the Oregon Board of Parole and Post‑Prison Supervision (the Board) paroled Jenkins from his last matrix sentence directly into service of his 15‑month guidelines term (he remained in custody).
On May 28, 2013 Jenkins committed an institutional assault; the Board treated this as a violation of parole condition "obey all laws" and revoked parole on August 20, 2013.
At a December 11, 2015 Future Disposition Hearing the Board imposed a 15‑year prison sanction for the parole violation; administrative review and state appellate review denied relief.
Jenkins filed a 28 U.S.C. § 2254 habeas petition arguing the Board never actually released him (so it lacked jurisdiction to impose parole conditions or revoke parole), raising due process challenges.
The federal district court denied the petition, holding state courts’ interpretation of Oregon law binding and finding no unreasonable application of clearly established federal law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Jenkins was ever "paroled" as a matter of state law and thus subject to Board jurisdiction	Jenkins: Because he was transitioned directly from matrix to guidelines custody (never released), the Board relinquished jurisdiction and could not impose enforceable parole conditions or revoke parole	Respondent: State law permits the Board to parole a prisoner from matrix sentences directly into a guidelines term and retain jurisdiction to impose and enforce parole conditions	Court: State courts implicitly rejected Jenkins’s statutory interpretation; federal habeas relief denied because state‑law determination is binding and no unreasonable application of Supreme Court precedent was shown
Whether the Board’s revocation and 15‑year sanction violated federal due process	Jenkins: Revocation based on nonexistent parole deprived him of due process protections	Respondent: Because Board properly retained jurisdiction, revocation and sanction were authorized; state procedures addressed review	Court: No federal due process violation shown; state court decision not objectively unreasonable

Williams v. Taylor, 529 U.S. 362 (framework for "contrary to" and "unreasonable application" under AEDPA)
Harrington v. Richter, 562 U.S. 86 (deference standard to state court decisions on habeas review)
Estelle v. McGuire, 502 U.S. 62 (federal habeas courts defer to state‑court interpretations of state law)
Delgado v. Lewis, 223 F.3d 976 (9th Cir. 2000) (independent review when state court gives no reasons)
Pirtle v. Morgan, 313 F.3d 1160 (9th Cir. 2002) (AEDPA deference principles on review of state decisions)
Shelby v. Board of Parole, 244 Or. App. 348 (Or. Ct. App. 2011) (Oregon appellate decision holding Board may parole directly from indeterminate to guidelines sentence and retain jurisdiction)