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Christopher A. Darden v. State of Mississippi

Citations: 227 So. 3d 1164; 2017 WL 4020603Docket: 2016-CP-01094-COA

Court: Court of Appeals of Mississippi; September 12, 2017; Mississippi; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves an appeal from a decision by the Greene County Circuit Court concerning the revocation of postrelease supervision (PRS) for an individual convicted of robbery in 2006. The appellant, who was sentenced to twelve years with five years of PRS, violated four PRS conditions, prompting the court to revoke his PRS and order him to serve the remainder of his sentence in the Mississippi Department of Corrections (MDOC). The appellant sought clarification on the revocation, arguing for credit for time served on PRS, assignment to a technical-violation center, and setting of a parole-eligibility date. The circuit court denied these motions, highlighting that credit claims should be addressed administratively, the court's discretion to revoke the full sentence after multiple violations, and the appellant's ineligibility for parole due to the nature of his conviction. The Court of Appeals affirmed the circuit court's decision, underscoring the necessity for the appellant to exhaust administrative remedies and reaffirming that Mississippi law does not provide credit for time served on PRS. The court's rulings reflect adherence to statutory provisions and case law applicable to PRS violations and parole eligibility.

Legal Issues Addressed

Credit for Time Served on Postrelease Supervision

Application: The court determined that claims for credit for time served on postrelease supervision must be resolved through administrative processes and not through post-conviction relief.

Reasoning: The 'street time' claim should be resolved through MDOC administrative processes; defendants are not entitled to credit for time spent on post-release supervision (PRS).

Parole Eligibility under Mississippi Law

Application: The court held that the appellant was ineligible for parole due to his armed robbery conviction involving a firearm.

Reasoning: Darden was not eligible for parole due to his armed robbery conviction. He was ineligible due to his conviction for armed robbery involving a firearm, as per Mississippi law.

Requirement to Exhaust Administrative Remedies

Application: The appellant was required to exhaust administrative remedies with the Mississippi Department of Corrections before pursuing judicial relief.

Reasoning: Darden failed to exhaust his administrative remedies with the Mississippi Department of Corrections (MDOC) regarding the time served calculation, leading the circuit court to correctly require him to seek administrative relief first.

Revocation of Postrelease Supervision

Application: The court exercised its discretion to revoke the full remaining sentence due to multiple violations of postrelease supervision conditions.

Reasoning: The circuit court determined Darden violated four PRS conditions, leading to the revocation of his PRS and the requirement to serve the remaining sentence in the custody of the Mississippi Department of Corrections (MDOC).