Joseph P. Dyer III v. James Bowlen, Warden
Court of Appeals for the Sixth Circuit
1Opinion of the Court
OPINION
RONALD LEE GILMAN, Circuit Judge.
In 1975, Joseph P. Dyer, III was convicted in a Tennessee state court on two counts of first-degree murder and on two counts of grand larceny. He was sentenced to death, but his sentence was commuted to life imprisonment because Tennessee’s death penalty statute was declared unconstitutional while Dyer’s direct appeal was pending. His convictions and sentence were affirmed on appeal.
When Dyer was granted his second parole hearing in 1998, the Tennessee parole board used the statutory parole standard in effect at the time of the hearing — rather than the…
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