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Bill Young v. R. Michael Cody, Warden
Citations: 943 F.2d 58; 1991 U.S. App. LEXIS 25953; 1991 WL 166401Docket: 91-7048
Court: Court of Appeals for the Tenth Circuit; August 28, 1991; Federal Appellate Court
Unpublished opinions may be cited if they hold persuasive value on material issues, provided a copy is attached to the citing document or furnished to the Court and all parties during oral arguments. Bill Young, the petitioner-appellant, appeals the denial of his habeas corpus petition following his 1986 conviction and ten-year sentence. He argues that the good time credit scheme at the time of his offense violates equal protection rights. A new scheme was enacted in 1988, which cannot be applied retroactively to disadvantage those convicted before its enactment, as established by the Oklahoma Court of Criminal Appeals. Consequently, inmates can earn good time credits under either the new or the original scheme, based on which is more favorable. Young contends he should earn credits under the most advantageous aspects of both schemes, a position rejected by state courts. He asserts a constitutional liberty interest in maximizing good time credits under both systems. The magistrate judge recommended summary dismissal of the case, deeming the issues primarily state law matters not cognizable under federal habeas statutes, and the district court upheld this dismissal. The appellate court affirmed the district court's dismissal of the liberty interest claim but remanded for further consideration of the equal protection claim, as the state had not yet responded. The court noted that existing Supreme Court and appellate decisions could provide relevant precedent. Young's due process claim regarding the inability to earn good time credits under both schemes was determined to lack support from federal or state law. No independent Constitutional liberty interest exists in a state's good time credit scheme, as established in Hewitt v. Helms and supported by prior cases. Although a good time credit system may suggest a liberty interest, the state does not have a mechanism that allows prisoners to earn credits from the most favorable aspects of different schemes. The court addressed the petitioner's claim that the older good time credit scheme violates equal protection by offering varying credits based on the nature of the work performed. Specifically, the petitioner argued that the system rewards work on state projects more than educational or vocational training, resulting in unequal credit for similarly situated prisoners. The petitioner also noted a discrepancy in credit earned for work at Oklahoma State Industries compared to the institutional garage. In evaluating this habeas corpus claim, the court determined that only a rational basis is required for the state's credit-awarding decisions and recognized the petitioner’s burden of proof. The court found insufficient evidence in the record to support the equal protection claim, leading to a decision to affirm part of the district court's judgment while vacating the remainder and remanding for further proceedings. The respondent-appellee opted not to file a brief, and the court decided against oral argument, stating that the ruling holds no precedential value except for specific legal doctrines.