In re Pers. Restraint of Lain

Petitioner Jerry Lain was sentenced to life under Washington's former indeterminate sentencing scheme. In 2010, the Indeterminate Sentencing Review Board found petitioner parolable, approved a release plan, and ordered parole with supervision. The governor revoked petitioner's parole. As a result, the Review Board tacked on 36 months to petitioner's minimum term of confinement. Petitioner challenged the revocation and additional term as-applied and facially, arguing that RCW 9.95.160 violated due process because it did not outline procedures for the governor to provide petitioner notice and an opportunity to be heard before the governor acted. The Supreme Court concluded the statute was constitutional on both its face and as applied to petitioner. View "In re Pers. Restraint of Lain" on Justia Law