MISSISSIPPI PAROLE  BOARD MEMBERS!!!

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ARGUMENT: ISSUE#1.WHETHER PETITIONER WILLIAMS IS ELIGIBLE FOR PARLOE DETERMINATION PURSUANT TO MISS.CODE ANN.47-7-3; THROUGH YEARS THE MISSISSIPPI PAROLE STATUE MISS. CODE ANN.47-7-3, HAS BEEN AMENDED MANY TIMES TO CHANGE AND ADD TO THE STATUE. HOWEVER THE MANDATORY LANGUAGE SET FORTH IN MISS.CODE ANN.47-7-3 WHICH HAS STOOD THROUGH THE TEST OF TIME REMAINS THE SAME, AND IT'S LANGUAGE MAKES PETITIONER WILLIAMS PAROLE ELIGIBLE...

MISS.CODE ANN.47-7-3:

EVERY PRISONER WHO HAS BEEN CONVICTED OF ANY OFFENSE AGAINST THE STATE OF MISSISSIPPI,AND IS CONFINED IN THE EXECUTION OF A JUDGMENT OF SUCH CONVICTION IN THE MISSISSIPPI DEPARTMENT OF CORRECTIONS FOR A DEFINITE TERM OR TERMS OF ONE (1) YEAR OR OVER,OR FOR THE OF THE TERM OF HIS OR HER NATURAL LIFE,WHOSE RECORD OF CONDUCT SHOWS THAT SUCH PRISONER HAD OBSERVED THE RULES OF THE DEPARTMENT AND WHO HAS SERVED NOT LESS THAN ONE-FORTH( 1/4) OF THE TOTAL OF SUCH TERM OR TERMS FIR WHICH SUCH PRISONER WAS SENTENCED ,OR ,IF SENTENCED TO SERVE A TERM OR TERMS OF THIRTY (30) YEARS OR MORE,OR IF SENTENCED FOR THE TERM OF THE NATURAL LIFE OF SUCH PRISONER,HAS SERVED NOT LESS THAN TEN(10) YEARS OF SUCH LIFE SENTENCE MAY BE RELEASED ON PAROLE AS HERE INAFTER PROVIDED."47-7-3.

PETITIONER WILLIAMS MEETS THE REQUIREMENTS FOR PARLOE ELIGIBILITY BECAUSE HE HAS BEEN CONVICTED OF TWO (2) OFFENSES AGAINST THE STATE OF MISSISSIPPI, "MANSLAUGHTER",& "AGGRAVATED ASSAULT" AND IS CONFINED IN THE EXECUTION OF A JUDGMENT OF SUCH CONVICTION IN THE MISSISSIPPI DEPARTMENT OF CORRECTIONS.WILLIAMS WAS SENTENCED TO A TOTAL OF( 40) YEARS ,(20)YEARS FOR MANSLAUGHTER ,AND (20) YEARS FOR AGGRAVATED ASSAULT.FOR THE ABOVE REASON (S) PETITIONER WILLIAMS IS PAROLE ELIGIBLE.

THE WORD "MAY" HOWEVER, DOES NOT MAKE WILLIAMS " PAROLE ELIGIBLE.---THAT'S A FACT.---OVER THE YEARS PAROLE BOARD MEMBERS HAVE GRANTED COUNTLESS PRISONERS PAROLE, THOUSANDS AND THOUSANDS BECAUSE PAROLE ELIGIBLE PURSUANT TO BEING CONVICTED OF OFFENSE AGAINST THE STATE OF MISSISSIPPI AND BEING CONFINED IN THE EXECUTION OF JUDGEMENT OF CONVICTION IN THE MISSISSIPPI DEPARTMENT OF CORRECTIONS .-----THE WORD" MAY" DOES NOT MAKE WILLIAMS INELIGIBLE FOR PAROLE ELIGIBILITY.DESPITE THE WORD "MAY" AND IT'S MANY MEANINGS,THE MISSISSIPPI  PAROLE STATUTE CREATES A CONSTITUTIONALLY PROTECTED LIBERTY INTEREST,SEE GREENHOLTZ VS .INMATES OF THE NEBRASKA PENA AND CORRECTION COMPLEX,442U.S.199S.CT.2100, 60 l ed.2d688(1979).

PETITIONER WILLIAMS ASSERTS THAT BY THE WORD OF THE STATUE, MISS. CODE ANN.47-7-3 . ENTITLES HIM TO PAROLE ELIGIBLITY."WHEN CONSTRUING THE MEANING OF A STATUTE,WE MUST LOOK AT THE WORDS OF THE STATUTE ." CALDWELL VS.N. MISS.MED CTR.,956SO.2D 888,890-91 (P10) (MISS.2007).WHEN WE DO SO ,OUR FIRST QUESTION...IS WHETHER THE STATUTE IS UNAMBIGUOUS ,THIS COURT APPLIES THE PLAIN MEANING OF THE STATUTE AND REFRAINS FROM THE USE OF STATUTORY CONSTRUCTION PRINCIPALS (SIC).GILMER VS.STATE, 955 SO.2D 829,833 (MISS.2007) ( CITATION AMITTED).THAT IS ,WHEN A STATUTES"LANGUAGE IS PLAIN,IT WILL BE ENFORCED AS WRITTEN."IN RE AB JR.663 SO.2D 580,581(MISS 1995).

PETITIONER WILLIAMS ASSERTS THAT IN REVIEWING HIS CLAIM AND MISS.CODE ANN.47-7-3 HE'S PAROLE ELIGIBLE, AND DUE TO 47-7-3 LANGUAGE" BEING AS PLAIN"AS IT IS, IT  SHALL BE ENFORCED AS WRITTEN,AND AS 47-7-3 IS WRITTEN PETITIONER WILLIAMS IS PAROLE ELIGIBLE...----WILLIAMS FURTHER ASSETS THAT ,MISS.CODE.ANN.47-7-3.IS UNAMBIGUOUS AND CAN ONLY BE UNDERSTOOD IN ONE WAY IN IT'S PLAIN LANGUAGE" AND SHALL BE ENFORCED AS WRITTEN GRANTING PETITIONER WILLIAMS PAROLE ELIGIBLITY.IN SUPPORT SEE SINKO VS.STATE,192SO.3D1069(MISS.2016), GILMER VS STATE,955 SO.2D829,833(MISS.2007)IN RE AB JR.663 SO.2D 580,581(MISS.1995).

PETITIONER WILLIAMS WOULD ASSERT HERE THAT MISS.CODE.ANN.47-7-3.IS UNAMBIGUOUS,AND ITS LANGUAGE IS PLAIN AND IT'S MEANING IS STRAIGHT FORWARD, BECAUSE PETITIONER WILLIAMS HAS BEEN CONVICTED OF "MANSLAUGHTER" AND  AGGRAVATED ASSAULT" AGAINST THE STATE OF MISSISSIPPI AND IS CONFINED IN THE EXECUTION OF JUDGEMENT OF SUCH CONVICTIONS IN THE MISSISSIPPI DEPARTMENT OF CORRECTIONS SERVING 20 YEARS FOR MANSLAUGHTER AND 20 YEARS FOR AGGRAVATED ASSAULT.PURSUANT TO MISS CODE.ANN 47-7-3. PETITIONER WILLIAMS IS PAROLE ELIGIBLE.UPON CONVICTION, WILLIAMS WAS NOT SENTENCED AS AN HABITUAL OFFENDER, MANSLAUGHTER AND AGGRAVATED ASSAULT" DOES NOT PROHIBITS PAROLE RELEASE, THEREFORE, PETITIONER WILLIAMS IS SUCH AN OFFENDER, AND HE MEETS THE REQUIREMENTS PURSUANT TO MISS.CODE.ANN.47-7-3 FOR PAROLE ELIGIBLITY...

PETITIONER WILLIAMS WOULD ASSERT HERE THAT HE WAS DENIED HIS  RIGHTS TO" EQUAL PROTECTION" SECURED TO HIM BY THE UNITED STATES CONSTITUTION.WHEN WILLIAMS COMMITTED THE CRIMES OF MANSLAUGHTER AND AGGRAVATED ASSAULT ON OR ABOUT JUNE 3RD 2011,MISS.CODE.ANN.47-7-3 STATED WHAT IT STATES NOW,WHEN WILLIAMS WAS CONVICTED AND SENTENCED ON OR ABOUT APRIL 11TH  2013, 47-7-3 STATED WHAT IT STATES TO THIS PERSENT DAY.THEN AND NOW PETITIONER WILLIAMS WAS "PAROLE ELIGIBLE".JUST LIKE ALL THE OTHER PRISONERS BEFORE WILLIAMS WHO WAD CONVICTED AND SENTENCED FOR CRIMES/OFFENSES COMMITTED AGAINST THE STATE OF MISSISSIPPI,  AND CONFINED IN THE EXECUTION OF A JUDGMENT OF SUCH CONVICTIONS IN THE MISSISSIPPI DEPARTMENT OF CORRECTIONS WERE " PAROLE ELIGIBLE PURSUANT TO MISS.CODE.ANN.47-7-3, PETITIONER WILLIAMS SHOULD BE" PAROLE ELIGIBLE" UNDER THIS SAME LAW, 47-7-3.

PETITIONER WILLIAMS FURTHER ASSETS THAT,PRIOR TO JULY .1,1995 EVERY PRISONER REGARDLESS OF THEIR RACE BECAME" PAROLE ELIGIBLE" PURSUANT TO MISS.CODE ANN.47-7-3 SIMPLY BECAUSE IT WAS THE LAW IN FORCE WHEN THE CRIME/OFFENSES CHARGED WAS COMMITTED MISS.CODE.ANN 47-7-3 WAS ALSO THE LAW IN FORCE WHEN PETITIONER WILLIAMS COMMITTED HIS CHARGED OFFENSES, THEREFORE, WILLIAMS SHOULD BE PAROLE ELIGIBLE .

RELIEF: 

WILLIAMS REQUESTED RELIEF IS THAT HE BE GRANTED PARLOE CONSIDERATIONS PURSUANT TO 47-7-3

 

JOSEPH WILLIAMS #N6787

THIS THE 21TH DAY OF NOVEMBER, 2019