Supreme Court of the United States
Lynce v. Mathis
February 19, 1997519 U.S. 433
Summary
The Court held that Florida's retroactive cancellation of previously awarded prison-overcrowding credits violated the Ex Post Facto Clause by prolonging petitioner's imprisonment after those credits had secured his release. The constitutional inquiry concerns the cancellation's effect on punishment, not the legislature's purpose in originally authorizing the credits. Later modifications to the credit system did not defeat petitioner's core claim, although the Court left for remand whether some credits exceeded what the statute in effect at the time of his offense would have authorized. Justice Stevens wrote for seven Justices. Justice Thomas, joined by Justice Scalia, concurred in part and in the judgment, agreeing that cancellation of credits already earned and used was unconstitutional but declining to join the discussion of Weaver and future credits.
Holding
- Whether retroactive cancellation of overcrowding credits unconstitutionally increases punishment.. Retroactively canceling petitioner's previously awarded overcrowding credits, thereby causing his rearrest and prolonging his imprisonment, violates the Ex Post Facto Clause.
- Whether intervening changes to the statutory credit system defeat petitioner's claim.. The later statutes' modifications did not defeat petitioner's core ex post facto claim because the earlier statute afforded substantially similar overcrowding credits. Whether cancellation of credits attributable solely to the later, lower population threshold was constitutional remained open on remand.
Docket 95-7452
Cited authorities
- Fla. Stat. § 944.598
- Fla. Stat. § 944.277
- Fla. Stat. § 947.146
- Fla. Stat. § 944.277
- Fla. Stat. § 944.598
- Fla. Stat. § 944.276
- Fla. Stat. § 944.277
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