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Washington Can’t Cheat Prisoner of Time Held Out of State on Washington Charges
Loaded on Jan. 1, 2022
by Jacob Barrett
published in Prison Legal News
January, 2022, page 58
Filed under:
U.S. Sentencing Guidelines,
Deportation/Removal/Exclusion,
Immigration Law/Offenses.
Location:
Washington.
But ICE Makes Sure That It Doesn’t Matter
by Jacob Barrett
On July 29, 2021 the Supreme Court of Washington ruled that a state prisoner was entitled to credit for all the time he was held in custody, even time outside the state, so long as he …
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More from this issue:
- Criminal Sheriffs, by Anthony Accurso
- From the Editor, by Paul Wright
- $150,000 Paid to Family of California Pretrial Detainee Who Died from Valley Fever, by David Reutter
- $650,000 Jury Verdict Upheld in NY Prisoner’s Excessive-Force Claim; Motion for Fees Denied Due to Contingency Agreement, by David Reutter
- St. Louis Jail Guard Charged with Allowing Brutal Beating of Prisoner, by Jayson Hawkins
- How Corrupt is Too Corrupt for Atlanta Federal Prison?, by Casey Bastian
- Do County Jails Treat Black Women Worse Than Other Prisoners?, by Kevin Bliss
- Former AZ Assistant AG Disciplined for Misconduct in Muslim Prisoner’s Lawsuit, by Douglas Ankney
- Washington Federal Court Grants Preliminary Injunction Halting Release of Transgender Prisoners’ Personal Information; Class Certified, by Jayson Hawkins
- USDA Gives $1,000,000 Grant to Corizon to Treat More Sick Prisoners Remotely, by Chuck Sharman
- Covid-19 Pandemic Bumps Still Anemic Clemency Numbers, by Edward Lyon
- Montana Renews CoreCivic Contract; Major Water and Sewage Problems Persist, by Jayson Hawkins
- California Federal Prison Warden Charged with Sexually Abusing Prisoner
- Should Sentencing Juries Consider Imprisonment Costs?, by Edward Lyon
- California Town Fighting to Keep Prison Open, by Keith Sanders
- Prosecutors Move to Close Case Against BOP Guards in Jeffrey Epstein Suicide, by Edward Lyon
- HRDC Advances in Suit Against Centurion to Obtain New Mexico Prisoner Medical Litigation Records, by David Reutter
- $281,000 Awarded to Colorado Prisoner Retaliated Against for Grievances, by David Reutter
- Indiana Supreme Court Denies Relief to Prisoner Whose Commissary Account Was Garnished, by Casey Bastian
- Colorado Using SWIFT but Cheap Wildlands Firefighters, by Edward Lyon
- Michigan Supreme Court Holds Convicted Prisoner Entitled to Pre-Trial Jail Time Credit
- Feds Declare Long COVID a Disability Under ADA, RA and ACA, by Edward Lyon
- Second Circuit Reverses Dismissal of NY Prisoner’s Due Process Claim on Grounds It Was Abandoned on Appeal, by David Reutter
- Corporations Using Prisoners to Fight Phantom Labor Shortage, by Matthew Clarke
- $500 Default Judgement in Female Michigan Prisoner’s Pro Se Excessive-Force Claim
- Federal Judge Springs Former PLN Editor from “Iron Man” Pretrial Detention Cell, by Casey Bastian
- Four Female Prisoners Seek Damages Over Abuses at Oregon Prison Called A “Cesspool” of Staff Sexual Abuse, Latest in Abuse Saga, by Mark Wilson
- Second Circuit: Supervisor Must Have Subjective Knowledge of Sexual Abuse by Guards to Be Liable
- Colorado Supreme Court Holds Governor Is Appropriate Defendant in Cases Involving State Constitutional Responsibility
- California Supreme Court: CDCR Cannot Exclude Nonviolent Sex Offenders From Proposition 57 Parole Consideration
- Fifth Circuit Dismisses Appeal by Mississippi Prisoner It Calls “Vexatious Litigant”
- Fifth Circuit Refuses to Issue Injunction After Mississippi Psychiatric Prison Improves Conditions, by Matthew Clarke
- Texas Agrees to Settlement Providing Prisoners Hep C Treatment, Will Pay $950,000 in Attorney Fees, by Matthew Clarke
- New Illinois Law Allows Early Release for a Few Eligible Offenders, by Casey Bastian
- $2 Million Paid by North Carolina Jail for Prisoner’s Wrongful Death; Undisclosed Amount Paid by Southeastern Medical Services, by Jacob Barrett
- $175,000 Awarded to New York Prisoner’s 686 Days Unconstitutional Post Release Supervision, by David Reutter
- Third Circuit Revives Pennsylvania Prisoner’s Lawsuit Over Censorship of Incoming Mail Containing Key Evidence, by Matthew Clarke, Dale Chappell
- Washington Can’t Cheat Prisoner of Time Held Out of State on Washington Charges, by Jacob Barrett
- NJ Supreme Court: Excess Time in Prison Must Be Used to Reduce Parole Period, by Matthew Clarke
- She Tried to Report Sexual Harassment in Jail. After Her Suicide, the Guard Was Convicted of Assaulting Four Other Women, by C.J. Ciaramella
- Seventh Circuit Holds Dismissal of Lawsuit Removed to Federal Court Cannot Count as PLRA “Strike”
- News in Brief
More from Jacob Barrett:
- $120,000 Settlement Reached With Long Island Detainee Assaulted by Jail Guards, July 15, 2023
- $17.675 Million Paid for New Yorker’s Wrongful Conviction, June 15, 2023
- Eighth Circuit Greenlights Arkansas Execution Protocol, June 15, 2023
- Second Circuit Upholds Connecticut Prison Porn Ban, Sets Up Circuit Split Over “Vagueness” Test, June 15, 2023
- Louisiana Sheriff Coughs Up $2.75 Million After Falsely Claiming Detainee Died From Accidental Fall, June 15, 2023
- Nevada Pays Over $568,000 for Denying Prisoner Cataract Surgery, Ends “One Good Eye” Policy, June 15, 2023
- Corizon Bankruptcy Threatens $6.4 Million Award to Family of Michigan Prisoner Whose Five-Day Jail Term Turned Into Death Sentence, June 1, 2023
- Detainee Allegedly “Eaten Alive” by Vermin in Overcrowded Atlanta Jail, May 1, 2023
- Ninth Circuit: Grievance Policy May Excuse Oregon Prisoner’s Failure to Exhaust Administrative Remedies, May 1, 2023
- Nevada Pays Over $568,000 for Denying Prisoner Cataract Surgery, Ends “One Good Eye” Policy, May 1, 2023
More from these topics:
- Tenth Circuit Announces Resentencing After Probation Revocation Must Begin with Chapter 7 Range, Holding Chapter 5 Range Should Be Considered When Deciding Whether to Vary, Sept. 1, 2026. U.S. Sentencing Guidelines, Revocation/Modification of Probation, etc., Statement of Reasons, Sentence, Factors To Be Considered.
- Relevant Conduct: How Federal Sentencing Law Punishes More Than the Crime of Conviction, Aug. 1, 2026. U.S. Sentencing Guidelines, Prior Conviction/Sentence/Incarceration, Plain Error, Acquitted Conduct/Uncharged Crimes/Dismissed Counts, Relevant Conduct.
- ICE Stops Reporting Deaths of Recently Released Detainees, July 1, 2026. Misconduct/Corruption, Medical, Conditions of Confinement, Immigration Law/Offenses, Civil Rights Actions or Offenses/Bivens Actions.
- U.S. Sentencing Commission: 2026 Amendments to the Federal Sentencing Guidelines, June 1, 2026. U.S. Sentencing Guidelines, Alternative Sentencing, Sentence Enhancements/Departures, Multiple/Multiplicious Counts, Drug Quantity.
- Fourth Circuit Announces ICE’s Execution of a Removal Warrant Following a Final Removal Order Does Not Constitute a “Pending Proceeding” Under 18 U.S.C. § 1505, Vacating Noncitizen’s Obstruction Conviction in Issue of First Impression, June 1, 2026. Deportation/Removal/Exclusion, Obstruction of Justice, Statutory Construction/Interpretation, Authority and Jurisdiction.
- First Circuit Vacates Drug Courier’s Sentence, Holding District Court Erred by Failing to Conduct Proper Comparative Culpability Analysis Under § 3B1.2 When It Excluded Other Participants in Drug Shipment From Universe of Comparators, May 1, 2026. U.S. Sentencing Guidelines, Mitigating Role/Circumstances/Evidence, Appellate Jurisdiction/Review, Sentencing Findings, Relevant Conduct.
- Sixth Circuit Announces Federal Coercion and Enticement Statute Requires Knowledge of Victim’s Minor Status, Deepening Circuit Split, May 1, 2026. U.S. Sentencing Guidelines, Sex Offender Registration and Notification Act, Statutory Construction/Interpretation, Sentence, Miscalculation of the Guidelines Sentencing Range.
- Tenth Circuit Holds Prior California Child Pornography Conviction Does Not Trigger Federal Mandatory Minimum Because State Statute Encompasses Conduct Beyond Federal Definition Under Categorical Approach, April 1, 2026. U.S. Sentencing Guidelines, Qualifying Offenses, Mandatory Minimum Sentence, Statutory Construction/Interpretation, Child Pornography.
- U.S. Sentencing Commission Report Breaks Down Federal Contraband Sentences, March 1, 2026. Guard Misconduct, Mechanical Searches/Scanners, Statistics/Trends, U.S. Sentencing Guidelines, Bribery/Extortion/Theft.
- Acquitted Conduct Sentencing: Not Guilty – But Punished Anyway, March 1, 2026. U.S. Sentencing Guidelines, Federal Legislation, Fifth Amendment, Sixth Amendment, Acquitted Conduct/Uncharged Crimes/Dismissed Counts.

