No Reduction Credits for 80-Year Life Sentences

The Supreme Court of North Carolina decided Lovette v. Department of Correction last Friday. The case has nothing to do with Laurence Lovette—the man found guilty of killing UNC student body president Eve Carson—whose case was also recently before our appellate courts (discussed here). Rather, it concerned Clyde Vernon Lovette and fellow petitioner Charles Lynch, two inmates serving life sentences for crimes committed in the mid-1970s. They committed their crimes during a four-year time period when a life sentence was defined in North Carolina as a term of 80 years. The supreme court decided last week that the men were not entitled to any reduction credits against their 80-year sentences, despite being convicted of crimes other than first-degree murder. To understand Lovette fully requires a look back at earlier chapters in the “80-year life” saga. Here is a review: Bowden. In State v. Bowden, 193 N.C. App. 597 (2008), the court of appeals held that under a former version of G.S. 14-2, a life sentence entered for an offense committed between April 8, 1974 and July 1, 1978, is an 80-year sentences for all purposes, including the determination of the inmate’s outright release date. As it was written at that time, G.S. 14-2 included a provision saying that a “sentence of life imprisonment shall be considered as a sentence of imprisonment for a term of 80 years in the State’s prison.” The Supreme Court of North Carolina initially agreed to review Bowden, but then decided that discretionary review had been improvidently [...]