Arkansas Parole Board John Felts, Brett Morgan, Andy Shock, Boyce Hamlet, Wendy Ryals, Jerry Riley, and Lona…

Summary

The court held that the Fair Sentencing of Minors Act's twenty-five-year parole-eligibility period for a juvenile convicted of first-degree murder applies only to the murder sentence and does not include a separate consecutive aggravated-assault sentence. Because the statute expressly addresses consecutive sentences in its nonhomicide provision but is silent on them in its homicide provision, the court applied the negative-implication canon and permitted the parole periods to be stacked. The court reversed the judgment granting immediate parole eligibility and remanded for recalculation of Johnson's parole-eligibility date.