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Hampton v. Louisiana Department of Public Safety & Corrections

Citations: 213 So. 3d 394; 2016 La.App. 1 Cir. 0402; 2017 WL 658730; 2017 La. App. LEXIS 247Docket: NUMBER 2016 CA 0402

Court: Louisiana Court of Appeal; February 16, 2017; Louisiana; State Appellate Court

Narrative Opinion Summary

This case involves an appeal by a prisoner contesting the denial of his administrative remedy request by the Louisiana Department of Public Safety and Corrections (DPSC). The appellant, previously convicted of armed robbery, had his good time release revoked after violating parole conditions. He challenged the DPSC's actions, arguing that his parole eligibility status was unjustly altered and that additional time was erroneously added to his sentence. The district court affirmed the DPSC's decision, finding that the correction of the appellant's master prison record was proper and aligned with the trial judge's sentencing order, which mandated serving the entire sentence without parole. The court also upheld the forfeiture of good time credits due to parole violations, as stipulated under relevant Louisiana statutes. The appeal further addressed the scope of appellate review, emphasizing that new arguments not raised in lower courts are typically not considered. Ultimately, the court upheld the DPSC's actions, dismissed the appellant's claims with prejudice, and assigned all costs of the appeal to him, reinforcing the statutory framework governing good time credits and parole eligibility for armed robbery convictions in Louisiana.

Legal Issues Addressed

Correction of Master Prison Record

Application: The DPSC's correction of Mr. Hampton's master prison record to remove the parole eligibility indication was in compliance with the trial judge's sentencing order.

Reasoning: The determination of sentence conditions is made by the trial judge, not the DPSC. Mr. Hampton did not dispute his sentence of 20 years without parole for armed robbery, and the DPSC’s actions to correct his record were in compliance with the trial judge's sentencing order.

Good Time Credit and Forfeiture

Application: An inmate who violates parole terms forfeits all earned good time credits and reductions toward their projected parole date, as stipulated in Louisiana statutes.

Reasoning: An inmate who violates parole terms forfeits all earned good time credits and reductions toward their projected parole date, as stipulated in La. R.S. 15:571.4(B)(2).

Judicial Review of Administrative Denial

Application: The district court, upon judicial review, affirmed the DPSC's denial of Mr. Hampton's administrative remedy and dismissed his petition with prejudice.

Reasoning: The commissioner later recommended affirming the DPSC’s denial of Mr. Hampton’s complaints, dismissing his petition with prejudice, and denying his motions. The district court adopted these recommendations on November 10, 2015, leading to Mr. Hampton's appeal.

Parole Eligibility for Armed Robbery Convicts

Application: Under Louisiana law, individuals convicted of armed robbery must serve their sentences without the possibility of parole, probation, or suspension.

Reasoning: Under Louisiana law, individuals convicted of armed robbery must serve their sentences without the possibility of parole, probation, or suspension.

Scope of Appellate Review

Application: Appellate courts generally do not address new issues not raised in the lower court, focusing instead on the matters presented and decided in the initial proceedings.

Reasoning: The only proper defendant in the judicial review was the DPSC, and Mr. Hampton's additional arguments beyond the scope of the appeal were not considered, as appellate courts generally do not address new issues not raised in the lower court.