Keys v. State
2011 Miss. LEXIS 389
| Miss. | 2011Background
- Keys pleaded guilty to murder in 1987 and received a life sentence with parole eligibility after ten years under the then-existing statute.
- MDOC paroled Keys in 1998, but revoked parole in 2002 for reasons not stated in the record.
- MDOC paroled Keys again in 2002; his five-year sentence for simple assault was consecutive to the life sentence, making him ineligible for parole on the five-year term as a subsequent offender.
- Keys sought parole-eligibility relief, which the trial court treated as post-conviction relief (PCR) and denied under § 99-19-21.
- Court of Appeals reversed, holding the trial court lacked jurisdiction; Mississippi Supreme Court granted certiorari and held the trial court had jurisdiction and Keys remains parole-eligible on the life sentence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the trial court's jurisdiction proper to hear Keys's petition? | Keys argues the petition is habeas/PCR and jurisdiction lies in circuit court. | State contends appellate lack of jurisdiction due to procedural exhaustion. | Trial court had jurisdiction. |
| Is exhaustion of MDOC administrative remedies required for parole-eligibility claims? | Exhaustion not required; relief may be sought directly in court. | Administrative procedures must be exhausted before court review. | Exhaustion not required. |
| Does § 99-19-21 impede parole eligibility on Keys's life sentence? | Statute does not impede parole on the life sentence; parole can occur before the five-year term begins. | Statute prevents parole on the life term until its end, delaying the five-year sentence. | § 99-19-21 is not an impediment to parole on the life sentence. |
| Whether Keys remains parole-eligible on the life sentence while serving the five-year sentence. | Parole eligibility on the life sentence remains in effect notwithstanding the five-year sentence. | Parole eligibility on the life sentence is affected by the imposition of the second sentence. | Keys remains parole-eligible on the life sentence; parole can occur, after which the five-year term begins. |
Key Cases Cited
- Williams v. Puckett, 624 So. 2d 496 (Miss. 1993) (parole/earned time computation claims without requiring exhaustion)
- Wilson v. Puckett, 721 So.2d 1110 (Miss. 1998) (post-conviction relief addressing parole eligibility without exhaustion)
- Lattimore v. Sparkman, 858 So.2d 936 (Miss.Ct.App.2003) (inmate may contest parole eligibility in circuit court)