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Washington Appeals Court Denies Prisoner's Prison Account Funds Suit
The Court of Appeals of the State of Washington has upheld the state superior court's grant of summary judgment in which James A. Boyd had challenged the authority of Washington State to deduct funds from his prison account for an order of a Kansas Court.
Boyd, sentenced in Kansas for a crime committed there, had been transferred under an Interstate Corrections Compact (ICC) to the State of Washington. Washington then began deducting funds from Boyd's account based upon their deduction statutes and rules. Boyd challenged this, arguing that the Washington "DOC's deduction of his funds under Washington's deduction statute violates Washington's version of the ICC and his state and federal due process rights."
Boyd's action, filed in Thurston County Superior Court, alleged that Washington had "infringed on his due process rights under the Fourteenth Amendment...and article I, section 3 of the Washington Constitution." The Superior Court denied him relief.
The Appellate Court agreed, citing Washington Law 72.74.020(3)(a)(ii) which provides that the receiving state shall receive funds for the sending state for "inmate maintenance, extraordinary medical and dental services, and any participation in or receipt by inmates of rehabilitative or correctional services..." Section 72.74.02(4)(a) provides that "the receiving state (may) act in that regard solely as agent for the sending state." Other provisions provided for transferred prisoners to be treated in the same manner as prisoners from the receiving state. Therefore, according to the court," Boyd's transfer contract expressly provides that the DOC may deduct... in the same manner as it deducts from other Washington inmate's wages."
The court further noted that "prisoners do not have a constitutional property interest in prison wages," and Washington State's deduction of wages from his prison account did not violate due process of law. See: Boyd v. Clarke, 160 Wash.App. 1002 (Wa. App. Div. 2 2011) (unpublished opinion); 2011 WL 444353.
Boyd, sentenced in Kansas for a crime committed there, had been transferred under an Interstate Corrections Compact (ICC) to the State of Washington. Washington then began deducting funds from Boyd's account based upon their deduction statutes and rules. Boyd challenged this, arguing that the Washington "DOC's deduction of his funds under Washington's deduction statute violates Washington's version of the ICC and his state and federal due process rights."
Boyd's action, filed in Thurston County Superior Court, alleged that Washington had "infringed on his due process rights under the Fourteenth Amendment...and article I, section 3 of the Washington Constitution." The Superior Court denied him relief.
The Appellate Court agreed, citing Washington Law 72.74.020(3)(a)(ii) which provides that the receiving state shall receive funds for the sending state for "inmate maintenance, extraordinary medical and dental services, and any participation in or receipt by inmates of rehabilitative or correctional services..." Section 72.74.02(4)(a) provides that "the receiving state (may) act in that regard solely as agent for the sending state." Other provisions provided for transferred prisoners to be treated in the same manner as prisoners from the receiving state. Therefore, according to the court," Boyd's transfer contract expressly provides that the DOC may deduct... in the same manner as it deducts from other Washington inmate's wages."
The court further noted that "prisoners do not have a constitutional property interest in prison wages," and Washington State's deduction of wages from his prison account did not violate due process of law. See: Boyd v. Clarke, 160 Wash.App. 1002 (Wa. App. Div. 2 2011) (unpublished opinion); 2011 WL 444353.
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Related legal case
Boyd v. Clarke
| Year | 2011 |
|---|---|
| Cite | 160 Wash.App. 1002 (Wa. App. Div. 2 2011) (unpublished opinion); 2011 WL 444353 |
| Level | State Court of Appeals |