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Prisoner Education Guide

Federal Circuit Reverses Prisoner’s Compensation Award by Court of Federal Claims

by Derek Gilna

Michael Alan Crooker, convicted of “mailing a threatening communication and possession of a toxin without registration,” received credit toward his federal prison sentence “for 2,273 days he spent imprisoned on a prior conviction for transportation of a firearm in interstate commerce by a convicted felon,” according to a ruling by the Federal Circuit Court of Appeals.

When Crooker’s prior conviction on the firearm charge was overturned on appeal, he sued the U.S. government for statutory compensation and was awarded $172,465.75 by the U.S. Court of Federal Claims. [See: PLN, March 2016, p.23]. Unfortunately for Crooker, that award was reversed by the Federal Circuit on July 12, 2016.

Crooker had made his original claim pursuant to the Unjust Conviction and Imprisonment Act, 28 U.S.C. §§ 1495 and 2513, which provides for compensation for time spent in prison when a conviction is overturned. That condition precedent occurred, according to the appellate ruling, when the “Court of Appeals for the First Circuit overturned Mr. Crooker’s conviction on June 18, 2010.” See: United States v. Crooker, 608 F.3d 94 (1st Cir. 2010). The conviction was reversed because while Crooker had been in possession of a silencer, there was no evidence that he “intended that the silencer be used with anything other than an air rifle.”

Both parties appealed the award by the Court of Federal Claims, with Crooker arguing that “he was entitled to damages for the full period he was imprisoned on the firearm charge” – that is, 2,553 days rather than the 1,259 days that formed the basis of the award. Federal officials argued that Crooker was entitled to no compensation.

“According to the government, the sentencing credit given to Mr. Crooker under § 3585(b)(2) in effect transferred the entirety of his time served on the Firearm Charge to the Toxin and Threat Charge,” the Court of Appeals wrote. Quoting the government’s brief, the Court continued, “Here, because Mr. Crooker received a full credit for every day he spent incarcerated (pursuant to 18 U.S.C. § 3585(b)) against his toxin/threat conviction, the time he spent imprisoned is connected to the toxin/threat conviction, and not the firearms conviction, and cannot serve as the basis for damages.”

The Federal Circuit agreed. “Mr. Crooker had the entirety of his imprisonment on the Firearm Charge credited to his sentence on the Toxin and Threat Charge. He thus already received compensation for his otherwise ‘unjust’ imprisonment. He is not entitled to monetary damages on top of this compensation.”

The appellate court concluded, “Because we find that there is no ‘period of incarceration’ attributable to Mr. Crooker’s ‘unjust’ conviction on the Firearm Charge, we hold that Mr. Crooker is entitled to no damages under the Unjust Conviction and Imprisonment Act.” See: Crooker v. United States, 828 F.3d 1357 (Fed. Cir. 2016). 

Related legal case

Crooker v. United States


 

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