Rhode Island General Laws

R.I. Gen. Laws § 13-8-10 (2026)

Prisoners subject to more than one sentence

✓ text as last checked Sept. 2026 (this copy records no edition or section history)
Find cases: SyfertCases citing this section RI-LEGwebserver.rilegislature.gov JustiaTitle on Justia CornellLII Search CasesGoogle Scholar

(a) If a prisoner is confined upon more than one sentence, a parole permit may be issued whenever he or she has served a term equal to one-third (⅓) of the aggregate time which he or she shall be liable to serve under his or her several sentences, unless he or she has been sentenced to serve two (2) or more terms concurrently, in which case the permit shall be issued when he or she has served a term equal to one-third (⅓) of the maximum term he or she is required to serve.

(b) If a prisoner, whether in confinement or on parole, is sentenced to serve a term of imprisonment for an offense which was committed after imposition of the sentence then being served, a permit may not be issued until he or she has served in confinement at least one-third (⅓) of the term of imprisonment to which he or she is sentenced for the subsequent offense. In calculating the date the prisoner shall become eligible for a permit, the time spent in confinement on an earlier imposed concurrent sentence shall not be credited for the purposes of parole eligibility on the subsequent sentence. In the event a prisoner is convicted of two (2) or more subsequent offenses and is sentenced to multiple terms of imprisonment for those offenses, the standards contained in subsection (a) of this section shall be used to determine when he or she has served one-third (⅓) of the terms of confinement imposed for the subsequent offenses and thereby is eligible for issuance of a permit under this subsection.

Notes of Decisions
Cited in 8 cases (2 in the last 5 years), 1980–2025 · leading case: Brown v. State, 32 A.3d 901 (R.I. 2011).
Brown v. State, 32 A.3d 901 (R.I. 2011). · cites it 14× “12 *907 Lastly, the hearing justice considered and dismissed Brown’s claim of unlawful incarceration, deeming Brown’s interpretation of the pertinent parole statutes as fundamentally flawed and “contrary to the legislature’s clear intent” in enacting § 13-8-10. Accordingly, the…”
Lerner v. Gill, 463 A.2d 1352 (R.I. 1983). · cites it 6× “General Laws 1956 (1981 Reenactment) § 13-8-10 provides that before being eligible for parole, a prisoner confined under consecutive sentences must serve at least one-third of the total of his sentences whereas a prisoner serving concurrent sentences becomes eligible for parole…”
DeCiantis v. State, 666 A.2d 410 (R.I. 1995). · cites it 9× “1956 (1994 Reenactment) § 13-8-10 to require the Board to grant applicant parole on the concurrent sentences.”
In re Advisory Opinion to the Governor, 421 A.2d 535 (R.I. 1980). · cites it 2× “Whereas in 1915 the determinative fraction for a prisoner serving a concurrent or consecutive sen *536 tence was one-half, here in the 1980s the fraction has been reduced to one-third, § 13-8-10. The eligibility time for a prisoner serving a life sentence has also been reduced…”
Skawinski v. State, 538 A.2d 1006 (R.I. 1988). · cites it 2× “” In those instances in which a prisoner is subject to the imposition of more than one sentence, § 13-8-10 provides in part that “(a) If such prisoner be confined upon more than one (1) sentence, such permit may be issued whenever he has served a *1008 term equal to one-third…”
Francisco Martinez v. State of Rhode Island, 328 A.3d 626 (R.I. 2025). · cites it 2× “1956] § 13-8-10, Mr. Martinez * * * would have parole eligibility determined by adding the minimum eligibility date of a life sentence to the minimum eligibility date of the consecutive term of years.”
Michael Lambert v. Wayne T. Salisbury, Jr., 336 A.3d 299 (R.I. 2025). · cites it 2× “Lambert argued that G.L. 1956 §§ 13-8-10 and 13-8-13 clearly required aggregation of the sentences.”
Lerner v. Gill, 580 F. Supp. 1056 (D.R.I. 1984). “provides that “In case of a prisoner sentenced to imprisonment for life, such permit (parole) may be issued at any time after such prisoner has served not less than ten (10) years imprisonment provided, however, in case of a prisoner serving a sentence or sentences of a length…”
R.I. Gen. Laws § 13-8-10(a): 2 cases
Brown v. State, 32 A.3d 901 (R.I. 2011). “12 *907 Lastly, the hearing justice considered and dismissed Brown’s claim of unlawful incarceration, deeming Brown’s interpretation of the pertinent parole statutes as fundamentally flawed and “contrary to the legislature’s clear intent” in enacting § 13-8-10. Accordingly, the…”
DeCiantis v. State, 666 A.2d 410 (R.I. 1995). “1956 (1994 Reenactment) § 13-8-10 to require the Board to grant applicant parole on the concurrent sentences.”
Annotations are extracted automatically from the opinions in the Syfert caselaw corpus and ranked by authority, recency, and treatment. Dots show Syfertize treatment of the citing case itself.