McGinnis v. Royster

Background

Two state prisoners (Royster and Rutherford) challenged a New York law, §230(3), that refused to count time they spent in county jails before trial as "good time" when calculating the earliest date they could appear for parole. Both men were unable to post bail and spent long periods in county jail (404 and 242 days). The prisoners argued that people released on bail before sentencing got better credit and that this treatment violated equal protection of the laws.

Reasoning

The Court considered whether the law had a rational basis. It explained that New York treats county jails mainly as detention centers, while state prisons provide organized rehabilitative programs, job training, and education. Good‑time allowances are tied to evaluation of conduct and progress in those programs. Because pretrial jail detainees are not under the State Correction Department’s supervision and are not participating in state rehabilitation programs, the Court found it reasonable to deny good‑time credit for pretrial county jail when setting the minimum parole date.

Real world impact

The Supreme Court reversed the three‑judge District Court and upheld the State’s distinction. The decision leaves in place a rule that can delay parole hearings for inmates detained pretrial in county jails, but it also notes a 1967 change in New York law that narrows the group affected; inmates convicted after September 1, 1967, are covered by a new scheme, and those eligible were offered the option to elect the new procedure.

Dissents or concurrances

Justice Douglas (joined by Justice Marshall) dissented, arguing the law discriminates against the poor who cannot make bail and that good time functions mainly as discipline, so the place of confinement should not change credit eligibility.