Watkins v. Secretary, Department of Public Safety & Correctional Services

BATTAGLIA, Judge.

The issue in this case is whether Division of Correction Directives (hereinafter “DCDs”) 100-105, 100-508, and 100-543, governing the security classification of inmates of the Division of Correction (hereinafter the “DOC”), are ex post facto laws and thus violate Article I of the United States Constitution and Article 17 of the Maryland Declaration of Rights. We hold that DCD 100-105, DCD 100-508, and DCD 100-543 do not constitute “laws” within the meaning of the ex post facto clauses of the United States Constitution and Maryland Declaration of Rights because they were…