New Mexico Supreme Court. Courtesy photo
COURT News:
SANTA FE — The New Mexico Supreme Court today upheld a New Mexico Corrections Department (NMCD) rule that prohibits prison inmates from receiving more than one lump sum award of good time credits for earning multiple educational degrees of the same level.
In a split decision, the Court concluded that the department’s rule “is not arbitrary and irrational but is reasonably related to the legitimate penological interests” of the Earned Meritorious Deduction Act (EMDA). The state law authorizes the department to award credits against an inmate’s sentence for completing approved vocational, substance abuse and mental health programs.
In the majority opinion, the Court for the first time adopted a legal standard for evaluating whether prison regulations infringe on an inmate’s constitutional rights. The standard is based on a U.S. Supreme Court decision in a 1987 case and requires a regulation to have a rational connection to a legitimate governmental interest in managing prisons.
The Court’s decision came in a case involving a prisoner, Steve Swayne, who completed two associate’s degrees. He was awarded a four-month reduction in his sentence for earning an associate of arts in liberal arts/university studies. Six months later, Swayne earned an associate of applied science in business administration, but the department denied him another four-month award of good time.
The department adopted a rule in 2013 that permitted one lump sum award of good time for each level of educational degree earned while in prison, from a high school equivalency degree through undergraduate and graduate degrees.
Swayne challenged the department’s rule by filing a petition of habeas corpus. A district court in Santa Fe struck down the rule, finding it arbitrary and capricious and not rationally related to the goals of the EMDA for rehabilitation of prisoners.
In appealing the district court’s decision, the department argued that its rule promoted higher educational attainment and prisoners with higher level degrees would have better employment opportunities upon their release.
The Court’s majority agreed and noted that Swayne was trying to earn a Bachelor’s degree, which would make him eligible for an additional five months of good time.
“In the absence of the NMCD rule, inmates might be disincentivized from taking the comparatively longer time needed to graduate with a Bachelor’s degree rather than undertaking multiple associate’s degrees,” the Court’s majority wrote in an opinion by Justice Briana H. Zamora. “Indeed, those interested only in shortening their sentences, rather than enhancing their skills or education, would pursue just such a strategy.”
The majority continued, “Thus, the rule encouraging prisoners to attain ever higher levels of education is rationally related to the rehabilitative goals of the EMDA because it assists prisoners in preparing to successfully reenter the community.”
Justice C. Shannon Bacon dissented from the majority decision. She concluded that the limitation on lump sum awards for the same level of educational degree was contrary to the legislative intent of the EMDA to promote good conduct by inmates and create educational opportunities for them.
“In actuality, the State’s claim otherwise is undercut by the facts of this case: regardless of the benefits of an advanced degree, Defendant’s employment opportunities were surely improved by adding the skills and credentials of his associate’s degree in business administration to his previously held associate’s degree in a distinct field,” Bacon stated.
“Significantly, the State’s rationale for the challenged NMCD policy is a policy decision by the agency, rather than by the Legislature,” Bacon wrote in the dissent, adding that reversing the district court in this case “comes dangerously close to providing the State with an improper rubber stamp.”
