Sentencing Guidelines

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7^th Circuit Court of Appeals

Case Name: Jason Wells v. Angela Caudill

Case No.: 18-2617

Officials: EASTERBROOK, RIPPLE, and SCUDDER, Circuit Judges.

Focus: Sentencing Guidelines

Jason Wells was sentenced in Illinois for two drug offenses: he received two years’ imprisonment for the first and one year for the second, to run consecutively. The sentencing judge gave him credit for pretrial detention: 255 days for the first sentence and 97 days for the second. Wells and the Illinois Department of Corrections promptly disagreed about how much time he needed to spend in prison.

Wells calculated his term as three years (1095 days) less 255 days less 97 days, for a total of 743 days. The prison system calculated 1095 less 255, for a total of 840. It disregarded the 97-day credit because it believed that, after his arrest for the second offense (which he committed while on bail from the first), Wells had been in custody on both charges simultaneously. The Department understands Illinois law to allow only the greatest of multiple credits to be applied when a person is in pretrial detention on multiple charges at the same time. See People v. Latona, 184 Ill. 2d 260, 271–72 (1998). Wells filed grievances, which were reviewed by several persons, including Angela Caudill, the Records Office Supervisor at East Moline Correctional Center. Although Wells did not articulate a legal position, the best would have been that he served sequential periods of pretrial detention (arrest, detention, release, rearrest, more detention), so that both credits should be applied even though he was in custody on two charges during the second period. But Caudill agreed with the calculation performed by one of her subordinates and initialed the worksheet. Wells was held until the expiration of the 840-day term (less good-time credits).

After his release, Wells filed this suit under 42 U.S.C. §1983, contending that Caudill and two other state employees violated the Cruel and Unusual Punishments Clause of the Eighth Amendment (applied to the states through the Fourteenth) by omitting the 97-day credit when determining his release date. The district court granted summary judgment to two of the defendants, ruling that they were not responsible for the calculation, and Wells has abandoned any claim against them. (Their names have been removed from the caption.) But the judge stated that the claim against Caudill required a trial to resolve two issues: who was right about the length of Wells’s sentences, and whether Caudill acted with the mental state required to violate the Eighth Amendment. The parties agreed to a bench trial, which was brief. Wells explained on the stand that he thought the prison system’s calculation mistaken, presented the state judges’ orders as evidence, and rested. The trial spans only 14 pages of transcript.

We have resolved this case as the litigants presented it. Because the district judge did not make a clearly erroneous finding when concluding that Wells had not shown that Caudill acted with the necessary state of mind, the judgment is affirmed.

Affirmed

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Derek A Hawkins is trademark corporate counsel for Harley-Davidson. Hawkins oversees the prosecution and maintenance of the Harley-Davidson’s international trademark portfolio in emerging markets.