Putnam v. Epps
2011 Miss. LEXIS 205
Miss.2011Background
- Putnam pled guilty in 1997 to armed robbery and was sentenced to 20 years, to run concurrently with a federal sentence.
- He is incarcerated in Yazoo County, Mississippi.
- Putnam sought post-conviction relief (PCR) arguing he is entitled to earned time and that MDOC miscalculated it and treated similarly situated prisoners differently.
- The Court of Appeals affirmed Yazoo County Circuit Court’s dismissal of his administrative-review petition as cognizable under the administrative-review procedure.
- Putnam exhausted MDOC administrative remedies and then filed a complaint under Mississippi Code Section 47-5-807 challenging MDOC’s earned-time computation, including equal protection arguments.
- The Yazoo County circuit court dismissed for improper venue; the case was transferred to determine proper venue and disposition on the merits.
- The Mississippi Supreme Court held that venue is proper in the First Judicial District of Hinds County and remanded for transfer; the first issue resolved in Putnam’s favor, making the second issue moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether venue was improper in Yazoo County. | Putnam; venue under 11-11-3(l)(a)(i) located where defendant resides or where act occurred. | Epps; Yazoo County proper under the administrative-review framework. | Venue proper in the First Judicial District; remand for transfer. |
| Whether Putnam was denied equal protection by not receiving earned time. | MDOC denial of earned time. similar prisoners granted earned time. | Challenge to earned time not within UP-CCRA or equal-protection grounds. | Not reached/ moot; court reversed for venue transfer, disposing of issue. |
Key Cases Cited
- Guy v. State, 915 So.2d 508 (Miss. Ct. App. 2005) (earned-time calculation not post-conviction relief; administrative-review remedy)
- Horton v. Epps, 966 So.2d 839 (Miss. Ct. App. 2007) (venue proper where act occurred; inmate actions located in Rankin County)
- Williams v. State, 669 So.2d 44 (Miss. 1996) (general principle on post-conviction relief considerations)