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Beginning in the Florida Legislature enacted a series of statutes authorizing the award of early release credits to prison inmates when the state prison population exceeded predetermined levels. In petitioner received a year prison sentence on a charge of attempted murder. In he was released based on the determination that he had accumulated five different types of early release credits totaling 5, days, including 1, days of "provisional credits" awarded as a result of prison overcrowding.

Shortly thereafter, the state attorney general issued an opinion interpreting a statute as having retroactively canceled all provisional credits awarded to inmates convicted of murder and attempted murder. Petitioner was therefore rearrested and returned to custody. He filed a habeas corpus petition alleging that the retroactive cancellation of provisional credits violated the Ex Post Facto Clause.

Relying on precedent rejecting this argument on the ground that the sole purpose of these credits was to alleviate prison overcrowding, the District Court dismissed the petition. The Court of Appeals denied a certificate of probable cause. To fall within the ex post facto prohibition, a law must be retrospective and "disadvantage the offender affected by it," Weaver v.

Graham, U. Youngblood, U. The operation of the statute was clearly retrospective, and a determination that it disadvantaged petitioner by increasing his punishment is supported by Weaver v.