Ughbanks v. Armstrong

Background

A man convicted of burglary in Michigan was sentenced in 1904 under the State’s 1903 indeterminate-sentence law. The sentence listed a minimum and (void) maximum; Michigan law sets five years as the statutory maximum for burglary. The prisoner also had two prior felony convictions. Michigan later passed a 1905 law repealing the 1903 act, but the Michigan Supreme Court held the 1903 law still applied to people already sentenced under it. The man challenged his continued imprisonment and argued his federal constitutional rights were violated.

Reasoning

The central question was whether applying Michigan’s indeterminate-sentence system to this man violated the Sixth, Eighth, or Fourteenth Amendments or amounted to an ex post facto law. The Court accepted the state court’s construction and prior federal decisions, explaining that the Sixth and Eighth Amendments do not limit the States in this context and that the Fourteenth Amendment does not prevent a State from attaching conditions to a discretionary parole privilege. The Court said parole is a favor granted by the governor under state rules, the State may exclude repeat felons from parole eligibility, and the convict has no federal right to a hearing on prior convictions. Because no federal right was shown, the Court affirmed the state judgment.

Real world impact

This ruling leaves control over maximum terms and parole eligibility with Michigan law as interpreted by its courts. People sentenced under the 1903 law remain governed by its terms; prisoners with two prior felonies are excluded from parole under that law. The decision enforces the governor’s broad discretion over parole and confirms that parole does not end the State’s legal custody.

Dissents or concurrances

Justice Harlan dissented from the judgment, expressing disagreement with the majority’s conclusion.