The People, Plaintiff and Respondent v. James Lee Brown Iii, Defendant and Appellant

Summary

The court held that the former version of Penal Code section 4019, which temporarily increased conduct-credit rates, operated prospectively and did not retroactively increase credits earned before its operative date. The statute contained no express or clearly implied retroactivity directive, and the special rule for statutes mitigating punishment did not apply because conduct credits reward future custodial behavior rather than alter the penalty for a completed offense. The court also held that prospective application did not violate equal protection because prisoners serving time before the incentive took effect were not similarly situated to prisoners who could modify their behavior in response to it.