parole
Georgia parole denials citing 'insufficient amount of time served': what the public record shows
This collection sets out facts from public sources on the subject in its title, drawn from Georgia, Florida and other sources. Each entry gives a short statement, the exact passage from the source that supports it, and the source's title, web address and the date it was retrieved. Searches of a source that found no match are listed too, with the wordings that were tried. The entries record what each source said when it was retrieved. They aren't a complete account of the subject, and they don't add analysis or conclusions.
Key Findings
The most impactful data from this research collection.
Denials Set 8 Years Out
PolicyNo Liberty Interest in Parole
Legal factFew Dozen Paroled, Thousands Denied
StatisticDenied Parole Five Times
Case detailParole Records Classified State Secrets
Legal fact30 Years Called Insufficient
Case detailAll Data Points
57 verified data points extracted from primary sources.
Board Rule 475-3-.05(2): Eight-Year Reconsideration for Life-Sentenced Inmates Legal fact
Board Rule 475-3-.05(2) states that reconsideration of life-sentenced inmates denied parole shall take place at least every eight years, and the Board will inform inmates denied parole of the reasons for such denial without disclosing confidential s…
Garner v. Jones: Parole Board discretion over reconsideration dates Legal fact
In Garner v. Jones, the law vests the Parole Board with discretion as to how often to set an inmate's date for reconsideration, with eight years for the maximum.
Board Policy: Life-Sentenced Denials May Be Set for Reconsideration Up to Eight Years Policy
The Board's Life Sentences page states it is the policy of the Board that all life-sentenced offenders denied parole may be set for reconsideration up to a maximum of eight years from the date of last denial when, in the Board's determination, it is…
AJC opinion: Parole Board gives no reasons for decisions Finding
An AJC opinion column by Bill Torpy states, in a photo caption, that the State Board of Pardons and Paroles gives no reasons for its approval or denial of parole decisions.
Pre-2006 Murder Life Sentence: 25-Year Minimum Before Parole Eligibility Legal fact
The Board's Life Sentences page states an offender convicted of murder and sentenced to life imprisonment before July 1, 2006, who has previously been imprisoned under a life sentence, must serve 25 years before becoming eligible for parole consider…
Sultenfuss v. Snow citation Legal fact
Sultenfuss v. Snow is reported at 35 F.3d 1494, an Eleventh Circuit Court of Appeals en banc decision from 1994.
Consecutive Life Sentences Pre-2006: Up to 30 Years Before Parole Eligibility Legal fact
The Board's Life Sentences page states an offender serving consecutive life sentences before July 1, 2006, one of which is for murder, for offenses occurring in the same series of acts, must serve consecutive ten-year periods for each such sentence,…
Sultenfuss v. Snow: No liberty interest in Georgia parole Legal fact
In Sultenfuss v. Snow, the Eleventh Circuit sitting en banc held that Georgia's parole system does not create a liberty interest in parole protected by the Due Process Clause.
July 2021: Attempted Serious Violent Felonies Raised to Crime Severity Level VIII Policy
As of July 2021, the Board increased the crime severity level for convictions of attempted aggravated child molestation, attempted armed robbery, attempted kidnapping, attempted aggravated sexual battery and attempted aggravated sodomy, from crime s…
Sultenfuss v. Snow: No legitimate expectation of parole Legal fact
In Sultenfuss v. Snow, the Eleventh Circuit en banc affirmed the district court's judgment that Georgia inmates do not have a legitimate expectation of parole protected by due process, because Georgia's parole system contains a statutory presumption…
January 2008 Parole Decision Guidelines Revision Preceded by Three-Year Study Policy
The Board's Parole Consideration, Eligibility & Guidelines page states that in January 2008 the Parole Board revised its Parole Decision Guidelines and changed the manner in which it evaluated offenders for cases considered on or after January 1, an…
Filter: Few dozen lifers granted parole, thousands denied without reason Statistic
Filter reported that Georgia's parole board grants mercy to only a few dozen parole-eligible lifers each year while a few thousand are left without any reason ever given to them.
Parole Decision Guidelines Begin with Crime Severity Level Identification Policy
The Board's Parole Consideration, Eligibility & Guidelines page states that the application of the Parole Decision Guidelines to the circumstances of the offender's case begins with a Board Hearing Examiner identifying the offender's Crime Severity …
Fuller v. Georgia State Board: Racial equal-protection claim rejected Legal fact
In Fuller v. Georgia State Board of Pardons & Paroles, the Eleventh Circuit held that Fuller, a Georgia inmate who challenged his parole denial on racial equal-protection grounds, failed to provide the 'exceptionally clear proof' of discrimination r…
Non-Life Denied Parolees Reconsidered at Least Every Five Years Policy
The Board's FAQ page states inmates serving non-life sentences who are denied parole will be automatically reconsidered by the Board at least every five years after becoming eligible for parole, and inmates serving life sentences who are denied paro…
Fuller v. Georgia State Board citation and date Legal fact
Fuller v. Georgia State Board of Pardons & Paroles is reported at 851 F.2d 1307, decided by the Eleventh Circuit Court of Appeals on Aug. 9, 1988.
Board Members May Override Guidelines Recommendation on Non-Life Cases Policy
The Board's FAQ page states that on non-life cases, Board Members determine whether the Guidelines recommendation for parole denial or for a tentative parole month (TPM) is appropriate, or whether mitigating or aggravating factors should override th…
Slakman appeal: District court docket and origin Case detail
The Eleventh Circuit's appeal of Barry Slakman's suit arose from D.C. Docket No. 1:20-cv-04822-SCJ in the Northern District of Georgia.
Board States Four Purposes of Prison Sentencing Policy
The Board's archived 'About Parole Consideration' page states that persons are sentenced to prison for four purposes -- punishment, incapacitation, deterrence, and rehabilitation -- and that a parole board studies the need for and accomplishment of …
Slakman appeal: Complaint dismissed and affirmed Case detail
In Slakman's appeal, the district court adopted the magistrate judge's Report and Recommendation and dismissed Slakman's complaint, and the Eleventh Circuit affirmed.
Board States Authority Allows Reduction of Sentence Disparity Policy
The Board's archived 'About Parole Consideration' page states the Board's unique central position and authority allows it to reduce sentence disparity, and that excessive harshness is more readily reduced, but excessive leniency in the form of a too…
Slakman appeal: Equal protection claim failed for lack of comparator engagement Legal fact
The Eleventh Circuit's opinion in Slakman's appeal ends with the word 'AFFIRMED,' holding that because Slakman did not engage with the 'many factors' that could have distinguished his purported comparators, he failed to state a claim for an equal pr…
Janice Buttrum Denied Parole Five Times Citing 'Not Enough Time Served' Case detail
Courthouse News Service reported that the Georgia Board of Pardons and Paroles has denied Janice Buttrum parole five times, citing 'not enough time served' based on her homicide conviction as the sole reason each time.
Garner v. Jones: Board declined to shorten reconsideration interval Legal fact
In Garner v. Jones, the Georgia Board of Pardons and Paroles, when it applied an amended rule extending the parole reconsideration interval to the respondent's case, declined to shorten that interval, citing his multiple offenses and the circumstanc…
Attorney Describes Parole Board Denial Letter Citing 'Nature of Your Offense' Finding
An attorney described receiving a Georgia parole board letter stating 'due to the nature of your offense you're being denied parole,' as quoted in the AJC's investigation of juvenile lifers.
Garner v. Jones: Georgia parole reconsideration timeline and Rule 475-3-.05(2) Legal fact
In Garner v. Jones, Georgia law required the Board of Pardons and Paroles to consider inmates serving life sentences for parole after seven years, and the Board's Rule 475-3-.05(2) originally required reconsiderations every three years before the Bo…
Incarcerated Person Quotes Parole Denial Letter: 'Due to the Nature of Your Offense' Quote
A person incarcerated in Georgia, interviewed by Filter, said his last parole denial letter stated 'due to the nature of your offense' as the reason. He stated: 'My last denial was about two years ago. They said "due to the nature of your offense...…
Garner v. Jones: Ex post facto controlling inquiry Legal fact
The Supreme Court in Garner v. Jones held that the controlling inquiry for an ex post facto challenge to a change in Georgia's parole reconsideration rule is whether the change creates a significant risk of prolonging the inmate's incarceration, and…
Filter Reports Parole Appeal Denials Often Delivered as Single Sentence Finding
Filter reported that Georgia parole board appeal denials are often delivered as a single sentence: 'Due to the nature of your offense...'
Fuller v. Georgia State Board: Plaintiff and claims Case detail
In Fuller v. Georgia State Board of Pardons and Paroles, the plaintiff was a Georgia inmate serving a life sentence for rape who brought a pro se civil rights action against the Parole Board, its members, and the Commissioner of the Georgia Departme…
Family Member Describes Board Denial Language: 'You Haven't Served Enough Time' Finding
GPB News quoted a family member, Roxanne Thompson, describing the Georgia parole board's denial language as: the board says, 'Due to the nature of your crime, you haven't served enough time.'
Fuller v. Georgia State Board: Quasi-judicial immunity for Board members Legal fact
The Eleventh Circuit held in Fuller that individual members of the Georgia Parole Board are entitled to absolute quasi-judicial immunity from a suit for damages, even though an inmate may challenge the denial of pardon or parole on equal protection …
Fuller v. Georgia State Board: Statistics on white rapists paroled more frequently Legal fact
The Eleventh Circuit in Fuller rejected the lifer's equal-protection claim because he failed to show he was similarly situated to white inmates who were paroled, even though his statistics showed white rapists were paroled more frequently than black…
Parole Board Records Classified as Confidential State Secrets Under O.C.G.A. § 42-9-53 Legal fact
The Georgia State Board of Pardons and Paroles states on its Open Records Request page that many records in its possession are classified as confidential state secrets under O.C.G.A. section 42-9-53.
Fuller v. Georgia State Board: Majority affirmed, Johnson dissent on equal protection Legal fact
The Eleventh Circuit majority in Fuller affirmed the district court's summary judgment for the Parole Board on the lifer's equal protection challenge to his denial of parole, which Judge Johnson's dissent disputed only as to that claim.
Day v. Bernard: Board Denied Parole in 2012 Citing 'Severe Nature of the Offenses' Case detail
In Day v. Bernard, Ga. Ct. App. No. A20A1019, the opinion states that in 2012 the Board denied Day parole on the ground that his release 'would not be compatible with the welfare of society... due to the severe nature of the offenses for which [he w…
Howard v. Coonrod: Class certification and dismissed claims Legal fact
In Howard v. Coonrod, the district court dismissed the Sixth Amendment and equal-protection claims and certified a Rule 23(b)(2) class for the remaining Eighth Amendment and due-process claims.
Day v. Bernard: Day Alleged Board Grossly Abused Discretion by Claiming Insufficient Time Served (30 Years) Case detail
In Day v. Bernard, the opinion states that Day alleged the Board grossly abused its discretion 'by claiming that he had served an insufficient amount of time (30 years)'.
Howard v. Coonrod: No liberty interest for juvenile lifers Legal fact
In Howard v. Coonrod, the Eleventh Circuit held that the juvenile lifers do not have a constitutionally cognizable liberty interest under either state law or the Eighth Amendment, and the court affirmed the district court's grant of summary judgment.
Day v. Bernard: Roger Day Sentenced to Two Consecutive Life Sentences Plus 100 Years Case detail
In Day v. Bernard, Roger Day was convicted of burglary, rape, and aggravated assault in 1990 and was sentenced to two consecutive life sentences, plus 100 years.
Howard v. Coonrod: Decision date and Florida parole challenge Legal fact
Howard v. Coonrod was decided by the Eleventh Circuit on April 15, 2025, an appeal from the Middle District of Florida challenging the way Florida's parole system applies to juvenile offenders.
Day v. Bernard: Court of Appeals Reversed Trial Court and Remanded Legal fact
In Day v. Bernard, the Court of Appeals of Georgia reversed the trial court's ruling denying the filing of Day's complaint and remanded with direction.
Howard v. Coonrod: Parties Case detail
In Howard v. Coonrod, the plaintiffs-appellants were Robert Earl Howard, Damon Peterson, Carl Tracy Brown, and Willie Watts, and the defendants-appellees were Melinda N. Coonrod, Richard D. Davison, and David A. Wyant.
Garner v. Jones: Supreme Court Reversed Eleventh Circuit on Retroactive Parole Rule Legal fact
In Garner v. Jones, the Supreme Court reversed the Eleventh Circuit's holding (164 F.3d 589) that the amended Georgia parole-reconsideration rule's retroactive application was necessarily an ex post facto violation, and remanded.
Jackson v. State Board: 1997 policy requiring 90 percent of term Legal fact
In Jackson v. State Board of Pardons and Paroles, the Board had amended its policy on December 9, 1997 to require that a prisoner convicted on or after January 1, 1998 of certain crimes, including aggravated assault, serve a minimum of ninety percen…
Garner v. Jones: Controlling Inquiry for Ex Post Facto Challenge to Parole Rule Change Legal fact
Garner v. Jones held that the controlling inquiry for an ex post facto challenge to a retroactive parole rule change is whether the change creates a sufficient risk of increasing the measure of punishment attached to the covered crimes.
Jackson v. State Board: Injunction and ordered parole hearing Legal fact
In the Jackson litigation, the district court granted Jackson's motion for equitable judgment, permanently enjoined the board from enforcing the new parole policy against him, and ordered the board to provide him an initial parole hearing.
Garner v. Jones Reported at 529 U.S. 244 (2000) Legal fact
Garner v. Jones is reported at 529 U.S. 244 (2000).
Data gap: No public record match for 'insufficient amount of time served' Data gap
A search of CourtListener for the phrases 'insufficient amount of time served,' 'nature and circumstances of your offense,' 'totality of your case,' and 'time served to date given the nature' returned no matches, indicating these denial reasons are …
Garner v. Jones: Georgia Law Requires Parole Consideration After Seven Years for Life Sentences Legal fact
In Garner v. Jones, Georgia law requires the State's Board of Pardons and Paroles to consider inmates serving life sentences for parole after seven years.
Data gap: No public record match for Griffin v. Nix parole Georgia Data gap
A search of CourtListener for 'Griffin v. Nix' parole Georgia returned 0 results, and searches for '2004-CV-92152' and 'Fulton Superior Court' also returned no match.
Garner v. Jones: 1989 Denial Set Reconsideration Eight Years Later Under 1985 Amendment Case detail
In Garner v. Jones, the Parole Board considered respondent for parole in 1989, seven years after his 1982 conviction, denied release, and consistent with the 1985 amendment to Rule 475-3-.05(2), set reconsideration for 1997, eight years later.
Parole Guidelines Not Applied to Life-Sentence Offenders; Offense Severity May Preclude Release Policy
The Board's Parole Guidelines page states that Board members do not apply Parole Decision Guidelines to life-sentence offenders, whose suitability for parole is dictated by the nature of their crime, and that offense severity may preclude any eventu…
Parole Decision Guidelines Used for Non-Life Cases Since 1979 Policy
The Board's Parole Guidelines page states that the Parole Board has reviewed non-life sentence cases under Parole Decision Guidelines, one of the country's first standardized methods of predicting success on parole, with a Board hearing examiner rev…
Time-Served Rule: Denial Throughout Confinement Triggers Consideration at One-Third of Sentence Legal fact
A Board rule on Time-Served Requirements for Parole Consideration states that if, upon the initial application of the Parole Decision Guidelines System, it is recommended that an inmate be denied parole throughout his or her confinement, the inmate …
Non-Life Inmates Considered Under Parole Decision Guidelines After Investigation Legal fact
A Board rule on Time-Served Requirements for Parole Consideration states that an inmate serving a sentence other than life imprisonment, for which parole consideration is authorized by law, is considered under Parole Decision Guidelines, and after i…
Data Gap: Parole Board Records Classified as Confidential State Secrets Limits Public Accountability Data gap
The Georgia State Board of Pardons and Paroles classifies many records as confidential state secrets under O.C.G.A. § 42-9-53, creating a significant data gap for researchers and the public seeking to understand parole denial patterns and the actual…
Sources
25 cited sources backing this research.
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Key Entities
Organizations, people, facilities, and other named entities referenced in this research.
Barry Slakman
[person]
Bill Torpy
[person]
Board Rule 475-3-.05
[legislation]
Day v. Bernard
[case]
Fuller v. Georgia State Board of Pardons & Paroles
[case]
Garner v. Jones
[case]
Georgia Board of Pardons and Paroles
[organization]
Georgia State Board of Pardons and Paroles
[organization]
Howard v. Coonrod
[case]
Jackson v. State Board of Pardons and Paroles
[case]
Janice Buttrum
[person]
O.C.G.A. § 42-9-53
[legislation]
Parole Decision Guidelines
[program]
Roger Day
[person]
Roxanne Thompson
[person]
Rule 475-3-.05(2)
[legislation]
Senate Bill 586
[legislation]
Sultenfuss v. Snow
[case]
Related Topics
Research topics that draw on data from this collection.
Legal Standards & Case Law
Georgia's prison conditions are governed by a half-century of Eighth Amendment doctrine — Estelle, Farmer, Wilson, Rhodes, Helling — that sets a two-part deliberate indifference test plaintiffs almost never clear: a Business Insider analysis of 1,488 federal prisoner complaints filed 2018–2022 found plaintiffs prevailed in 11 cases, and just 1% of Eighth Amendment claims succeeded (Slow Starvation in Georgia Prisons). The rules that matter most in Georgia were written by the Eleventh Circuit: the en banc Wade v. McDade decision of July 2024, which requires proof that an official's own conduct created the risk, now governs every conditions case in Georgia, Florida and Alabama, and the court has never issued a published opinion holding prolonged solitary confinement unconstitutional. In October 2024 the U.S. Department of Justice found that Georgia and GDC engage in a 'pattern or practice' of Eighth Amendment violations across its prisons; as of May 2026, no consent decree and no CRIPA enforcement suit had followed.
5,874 data points
Oversight & Accountability
Georgia runs the largest prison system in the country without a single independent oversight body — no ombudsman, no inspector general for corrections, no external monitor, and no public reporting requirement attached to the $600 million it has poured into the system. Every institution that is supposed to catch what goes wrong inside GDC — the grievance process, the PREA audit regime, the ACA accreditation cycle, the internal ombudsman, the death investigation chain — is either run by GDC or dependent on GDC for access, funding, or paperwork. The result, documented across 89 GPS research collections, is a system that audited itself to a 100% compliance record while the U.S. Department of Justice found 'horrific and inhumane' conditions, misreported homicides by a factor of three, and left 82 recommended remedies unimplemented with no consent decree in sight.
11,953 data points
Parole & Sentencing
Georgia's parole system has contracted to a fraction of its former output: parole releases fell 42% between FY19 and FY24, the Board's overall grant rate hit a record-low 28% in FY24, and only 4.5% of the 2,046 life-sentence cases decided that year ended in release. At the same time, the average time served on a life sentence before release rose from under nine years in 1973 to 29.6 years in FY25. The result is a release regime in which most people now leave prison by serving out their maximum sentence rather than by parole, and in which people die waiting — including people whose release dates were already set.
11,774 data points