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U.S. Court of Claims Awards Federal Prisoner $172,465.75 for Wrongful Conviction

Michael Alan Crooker, wrongfully convicted in Massachusetts on a federal charge of being a felon in possession of a firearm, had his conviction reversed on appeal by the First Circuit in 2010, setting the stage for a certificate of innocence and a claim for financial damages from the federal government for $50,000 for each year he was imprisoned. According to his attorney, he was entitled to an award in excess of $300,000. Then things got complicated.

The U.S. Department of Justice hates to be embarrassed, so when Crooker appealed his firearm conviction – which involved the sale of a silencer designed for an airgun – he was indicted on other charges for possessing toxins and writing threatening letters to government officials. Convicted of those charges, he was sentenced to 180 months in federal prison. As a result, the government’s opposition to Crooker’s claim for damages for wrongful imprisonment centered on his receiving credit on his sentence on the subsequent charges for time served on the wrongful firearm conviction. Both parties moved for summary judgment.

According to the Court of Claims, “The Court concludes that the material facts of this case are not in dispute and that the parties’ cross motions for summary judgment present purely legal issues. Regarding those issues ... the Court concludes that Mr. Crooker’s receipt of a sentencing credit pursuant to the requirements of 18 U.S.C. § 3585(b)(2) does not divest him of his right to an award of compensatory damages for his unjust conviction and imprisonment pursuant to the unjust conviction statutes.... On the other hand, the Court agrees with the government that it is appropriate to cut off Mr. Crooker’s entitlement to damages as of the date of his indictment on the threat and toxin charges....”

The Court of Claims found that “Mr. Crooker is entitled to damages up to the statutory cap for this period of incarceration, resulting in an award of $172,465.75” for his time spent in custody from his arrest in June 2004 through his 2007 indictment on the additional charges. “Further, his receipt of a sentencing credit for time already served on the firearms conviction was not a product of agreement; it occurred by operation of law ... the reason the time may be credited against his sentence on the threat and toxin charges at all is that it was not lawfully credited to the firearms charge.” See: Crooker v. United States, 119 Fed.Cl. 641 (Fed. Cl. 2014).

Crooker remains incarcerated on his subsequent convictions and 180-month sentence, with a release date in September 2017. In this case a valid claim of innocence resulted in additional charges and prison time, though at least Crooker will not be leaving the federal prison system empty-handed. 

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Related legal case

Crooker v. United States