Bernard Jones v. Dave Bergman, Warden

CLAIM I: Whether a prisoner has a constitutional right to have all of his jail time deducted from his sentence of incarceration irrespective of his parole eligibility date being discretionary or non-discretionary under the Due Process Clause of the United States Constitution. CLAIM II: Whether a prisoner has a constitutional right to have all of his jail time deducted from his sentence of incarceration irrespective of his parole eligibility date being discretionary or non-discretionary under the Equal Protection Clause of the U.S. Constitutions’ 14th Amendments if Colorado Department of Corrections is deducting the total amount of jail time for other prisoners to determine their correct Parole Eligibility Date. Claim III: Whether a State agency can evade the application of the factors that the United States Supreme Court has established to determine a violation of the Ex Post Facto Clause of the United States Constitution by creating a new and novel method for calculating a prisoner’s initial parole eligibility date by adding eight years after he served over twenty years in prison. CLAIM IV: Whether a State Supreme Court can evade the application of the factors that the United States Supreme Court have established to determine a violation of the Due Process Clause under the 5th and 14th Amendments of the United States Constitution based on the Ex Post Facto Clause when it fails to cite the specific state case law that would put Mr. Jones on notice that it could add eight years to his parole eligibility date when its prior decisions specifically sanctioned the previous method for calculating a prisoner’s initial parole eligibility date.