State v. Bischoff

Summary

The court held that the 2015 amendment reducing the penalty for first-offense narcotics possession applied prospectively only, so the defendant was properly sentenced under the law in effect when he committed the offense. The court reasoned that the savings statutes create a presumption against retroactive application of changes to criminal punishment, and the amendment contained no explicit retroactivity language or ambiguity requiring resort to legislative history. The court also declined to adopt the amelioration doctrine or overrule its prior rejection of that doctrine.