Commonwealth v. Cullen-Doyle, S., Aplt.

OPINION

CHIEF JUSTICE SAYLOR

This matter concerns a statutory risk reduction incentive program, eligibility for which requires that the offender lack a “history of present or past violent behavior.” The question presented on appeal concerns whether a single conviction for burglary—which the parties agree is a crime demonstrating violent behavior— constitutes such a history.

In 2009, the General Assembly codified the Recidivism Risk Reduction Incentive Act (the “RRRI Act” or the “Act”), as Chapter 45 of the Prisons and Parole Code.1 The Act is intended to encourage eligible offenders to complete…