Lindsey v. Washington

Background

A group of people convicted of grand larceny in Washington were sentenced after a new 1935 state law changed how prison terms and parole were handled. When the crimes were committed the law allowed a court to set both minimum and maximum terms and courts could set a minimum less than the fifteen-year maximum. The 1935 law, passed after the crimes but before sentencing, told courts to fix only the maximum term and gave a parole board six months to fix the actual duration of confinement, with power to revoke or change that duration. The law also limited early release credits to at most one-third of the board-fixed term and allowed the governor to cancel paroles.

Reasoning

The Court compared how the old and new laws actually worked. Under the earlier law a court could give a sentence shorter than fifteen years and free a person from custody and parole control sooner. The new law made the fifteen-year maximum mandatory and left prisoners subject to parole control and revocation for the entire period. The Court said the Constitution forbids imposing a new, more onerous system of punishment on someone for a crime committed before the change. Because the later law raised the standard of punishment in practice, applying it to these convictions was unconstitutional. The Court reversed the state court’s decision and sent the case back for further proceedings.

Real world impact

The ruling prevents states from retroactively using tougher sentencing and parole rules to keep people confined longer or under stricter control than the law in effect when the crime occurred. Whether the prisoners should be resentenced under the earlier law is left to the state court.