University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name People v. McOwens JC-CA-0012
Docket / Court 10016 ( State Court )
State/Territory California
Case Type(s) Jail Conditions
Case Summary
This case is a challenge in California state court of pre-sentence custody time credit for a criminal defendant, following a federal court decree concerning work time credits for certain inmates.

In the earlier case (whose title we do not know), the United States District Court for the ... read more >
This case is a challenge in California state court of pre-sentence custody time credit for a criminal defendant, following a federal court decree concerning work time credits for certain inmates.

In the earlier case (whose title we do not know), the United States District Court for the Eastern District of California issued a consent decree on August 4, 1987, concerning overcrowding conditions at the jail in Yolo County, California (JC-CA-017). The consent decree provided that in order to maintain the inmate population cap, and notwithstanding California state law, the sheriff was authorized to extend the California Penal Code section 4024.2 work program to incarcerated inmates. Qualifying inmates were eligible to have one day of their sentence deducted for each day of work performed provided they stay in the jail at night while participating in the work program.

The defendant in this case, Reginald McOwens, pled guilty to first degree burglary, and on June 27, 1988, the trial court placed McOwens on probation for three years with a condition that he be confined to the county jail for 180 days. The sheriff released McOwens after he served 73 days of the sentence. On March 14, 1989, McOwens admitted violating probation. The trial court revoked probation and sentenced McOwens to state prison for four years. The trial court found that McOwens worked at least eight hours in the county jail on 21 of the 73 days he spent in the jail's custody, and accordingly awarded McOwens 21 days of work credit to be deducted from his four year state prison sentence. The state of California appealed to challenge the award of 21 days of pre-sentence custody credit.

On June 28, 1990, the Third District Court of Appeals of California (Judge Puglia) held that McOwens' participation in a work program while incarcerated in the county jail as a condition of probation did not entitle him to pre-sentence custody credits to be applied against his later state prison sentence. People v. McOwens, 270 Cal.Rptr. 756 (Cal. Ct. App. 1990) (unpublished decision). The Court also ruled that it did not have the authority to set aside California state law to find McOwens eligible for the work credits even if the federal court consent decree required that the McOwens be awarded such credits.

The docket in this case was not available on PACER because the case did not arise in the federal courts. Accordingly, we have no further information.

Tom Madison - 03/04/2006


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Issues and Causes of Action
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Issues
Affected Gender
Male
Crowding
Crowding / caseload
Pre-PLRA Population Cap
General
Classification / placement
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action State law
Defendant(s) Yolo County
Plaintiff Description Participant in a prison work program
Indexed Lawyer Organizations None on record
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer No
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year n/a
Case Ongoing Unknown
Case Listing JC-CA-0017 : Re: Yolo County Jail (E.D. Cal.)
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
No docket sheet currently in the collection
General Documents
Reported Opinion 06/28/1990 (270 Cal.Rptr. 756)
JC-CA-0012-0001.pdf | WESTLAW| LEXIS | Detail
Document Source: Westlaw
Judges Puglia, Robert K. (State Appellate Court)
JC-CA-0012-0001
Monitors/Masters None on record
Plaintiff's Lawyers Granberg, Derald E. (California)
JC-CA-0012-0001
Iglehart, Richard B. (California)
JC-CA-0012-0001
Nelson, Shirley A. (California)
JC-CA-0012-0001
Van de Kamp, John K. (California)
JC-CA-0012-0001
Defendant's Lawyers Segerstrom, Donald I. (California)
JC-CA-0012-0001
Other Lawyers None on record

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