Terrence Clark v. Mississippi Department of Corrections
148 So. 3d 403
| Miss. Ct. App. | 2014Background
- Terrence Clark, an MDOC inmate, serves three consecutive sentences: two as a habitual offender (armed robbery and burglary) and one non-habitual (possession of contraband).
- Clark requested meritorious earned time in February 2012; MDOC informed him habitual-offender sentences made him ineligible, though the two-year non-habitual sentence might qualify.
- Clark filed MDOC grievances through the Administrative Remedy Program and was denied at both levels.
- He sought judicial review in Carroll County Circuit Court (motion to show cause or post-conviction relief); the circuit court affirmed MDOC’s denial.
- Clark appealed to the Mississippi Court of Appeals, arguing denial of due process and equal protection for refusal to grant meritorious earned time.
- The Court of Appeals affirmed, concluding MDOC’s denial was supported by law and not arbitrary or capricious.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Eligibility for meritorious earned time | Clark: habitual convictions should not bar meritorious earned time; denial violated due process and equal protection | MDOC: Habitual-offender status makes inmate ineligible under statutory scheme and MDOC discretion | Affirmed: habitual-offender status bars meritorious earned time; MDOC acted within authority |
| Administrative-review standard | Clark: MDOC decision deprived him of rights without proper review | MDOC/State: decision supported by statute and within agency discretion | Affirmed: decision supported by substantial evidence; not arbitrary or capricious |
Key Cases Cited
- Siggers v. Epps, 962 So. 2d 78 (Miss. Ct. App. 2007) (standards for judicial review of agency decisions)
- Edwards v. Booker, 796 So. 2d 991 (Miss. 2001) (agency decision review standard referenced)
- Brandon v. Miss. Emp’t Sec. Comm’n, 768 So. 2d 341 (Miss. 2000) (abuse-of-discretion standard for trial court review of agency rulings)
- Green v. Sparkman, 829 So. 2d 1290 (Miss. Ct. App. 2002) (meritorious earned time is within MDOC discretion)
- Smith v. State, 75 So. 3d 82 (Miss. Ct. App. 2011) (habitual offenders ineligible for earned time)
- Lee v. Kelly, 34 So. 3d 1203 (Miss. Ct. App. 2010) (earned time characterized as reduction in sentence)
- Williams v. State, 98 So. 3d 484 (Miss. Ct. App. 2012) (habitual-offender sentencing bars parole, probation, and earned-time allowance)