Zuther v. State

OPINION

JONES, Vice Chief Justice.

I. INTRODUCTION

¶ 1 Reinhold F. Zuther was convicted of a felony in 1992 and sentenced to prison. At the time of the conviction, A.R.S. § 31-228 required the Arizona Department of Corrections (ADOC) to provide the sum of $50 in “gate money” to each prisoner upon release from prison unless the inmate had more than $250 otherwise available.

¶ 2 On April 22,1993, the legislature enacted A.R.S. § 31-237, effective immediately, which created a “dedicated discharge account” for each inmate and required ADOC to deposit a percentage of inmate prison wages into the…