Case: People v. McOwens

No. C006755 | California state appellate court

Filed Date: 1989

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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 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 maintai…

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.

Summary Authors

Tom Madison (3/4/2006)

Related Cases

Re: Yolo County Jail, Eastern District of California (1987)

People


Judge(s)

Puglia, Robert K. (California)

Attorney for Plaintiff

Granberg, Derald E. (California)

Iglehart, Richard B. (California)

Nelson, Shirley A. (California)

Attorney for Defendant

Segerstrom, Donald I. (California)

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Documents in the Clearinghouse

Document

No. C006755

Reported Opinion

June 28, 1990

June 28, 1990

Order/Opinion

270 Cal.Rptr. 270

Docket

Last updated Aug. 30, 2023, 2:38 p.m.

Docket sheet not available via the Clearinghouse.

Case Details

State / Territory: California

Case Type(s):

Jail Conditions

Key Dates

Filing Date: 1989

Case Ongoing: No reason to think so

Plaintiffs

Plaintiff Description:

Participant in a prison work program

Plaintiff Type(s):

Private Plaintiff

Public Interest Lawyer: Unknown

Filed Pro Se: Unknown

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

Yolo County (Yolo), State

Case Details

Causes of Action:

State law

Available Documents:

Any published opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Classification / placement

Jails, Prisons, Detention Centers, and Other Institutions:

Crowding / caseload

Pre-PLRA Population Cap

Affected Sex or Gender:

Male

Type of Facility:

Government-run