Sullivan v. Benningfield

In May 2017, Judge Benningfield issued an order offering a 30-day sentencing credit to White County, Tennessee inmates in exchange for submitting to sterilization. After public outcry, Judge Benningfield declared that inmates could no longer enroll in the program. A third order clarified which of the inmates who initially enrolled could still receive the credit. Within months, the Tennessee Legislature passed Senate Bill 2133, which made it illegal for courts to make sentencing determinations based on a defendant’s willingness to consent to sterilization. Three inmates who refused to submit to a vasectomy and were consequently denied the sentencing credit challenged Judge Benningfield’s orders under the Equal Protection Clause. The district court found that the claims were moot. The Sixth Circuit reversed, reasoning that none of those subsequent developments in the law ended the differential treatment that plaintiffs challenged. Plaintiffs alleged that awarding them the 30- day sentencing credit would affect other collateral consequences related to sentencing. Tennessee law permits non-violent offenders to petition for expungement five years after the sentence termination date so that retroactive application of the sentencing credit would allow them to pursue expungement 30 days sooner. View "Sullivan v. Benningfield" on Justia Law