The New Mexico Supreme Court upheld a state policy that restricts the amount of time inmates can reduce their sentences by earning educational degrees while in prison. The ruling issued last Monday affirmed the existing policy of the New Mexico Corrections Department (NMCD), which offers sentence reductions to inmates who have achieved certain educational milestones.
The recent ruling upheld by the NM Supreme Court came after inmate Steve Swayne challenged the NMCD rule after earning two associate degrees during his incarceration. After receiving a four-month reduction for his first associate degree in liberal arts/university studies, Swayne was denied additional credit when he completed a second associate degree in applied science with a business administration specialization six months later.
Swayne argued that the denial violated the Earned Meritorious Deductions Act (EMDA), a New Mexico state law designed to incentivize inmates by reducing their prison sentences when they complete educational or rehabilitative programs.
However, the Supreme Court disagrees with Swayne’s and the lower court’s argument. Justice Briana H. Zamora stated that the NMCD policy appropriately aligns with the EMDA’s goal of promoting advancement to higher educational levels, rather than merely repeating the same level of education.
Justice Zamora emphasized that without this restriction, inmates could simply pursue multiple associate degrees to continually shorten their sentences, rather than pursuing bachelor’s or graduate degrees.
Justice C. Shannon Bacon, however, offered a dissenting view regarding this matter. She argued that the EMDA broadly supports rewarding all educational achievements at all levels, as each degree enhances inmates’ opportunities for employment post-release. She concluded that the rule is overstepping the statute’s purpose.
The NM Supreme Court’s decision marks the first time it has explicitly applied a standard from the landmark U.S. Supreme Court case Turner v. Safley (1987) that tests whether prison regulations serve legitimate correctional objectives.
Experts and policymakers have highlighted the importance of higher education programs in reducing recidivism. Data shows that inmates who achieved higher educational degrees significantly increase their chances of successful reintegration into society upon release.
New Mexico prisons offer various educational opportunities through partnerships with institutions like Eastern New Mexico University, which is primarily focused on vocational skills and distance learning. Recent legislative developments, such as Senate Bill 375, also support the opportunities inmates could earn credits for good behavior and educational advancement.
The court’s decision aims to encourage inmates to pursue more substantial educational achievements to help prepare them for re-entry into society. This policy aligns with broader efforts in the state to enhance rehabilitative opportunities for prisoners.
