Keeping Time Aligned: The Significance of Leap Years
Leap years were created to harmonize calendar years, which consist of 365 days, with astronomical years, which span 365.2425 days. Occurring every four years, leap years only take place on years divisible by 4. This rule, however, has a minor exception: if a year is divisible by 100 (such as 1800 and 1900), it is not a leap year. Interestingly, a further exception to that exception exists – if a year is divisible by 400 (like 1600 and 2000), it is indeed a leap year. Therefore, as we mark February 29 on our calendars this year, we can confidently assert that 2020 is indeed a leap year.
Implications in the Legal Field: Contracts, Limitations, and Sentencing
In the realm of law, where deadlines and timelines are of utmost importance, it is only natural to question the implications of leap years. Contractual calculations, determining statutes of limitations, and establishing criminal sentencing are areas where the impact of leap years becomes evident.
When it comes to determining the time limit for statutes of limitations or setting the duration of criminal sentences, February 29 is counted as a separate day when the length of time is specified in days. However, if the length of time is expressed in years, the extra day seemingly disappears, and a leap year is treated as a common year for legal purposes.
Despite the apparent resolution of this matter, leap years and their legal implications continue to surface frequently in courtrooms. This is exemplified by the case of Habibi v. Holder, decided on December 8, 2011. Jawid Habibi had been convicted of Battery of a Current or Former Significant Other, a misdemeanor under California law. Habibi received a 365-day sentence that would extend into the leap year of 2000. Subsequently, the Department of Homeland Security attempted to deport Habibi on the grounds that his California conviction rendered him liable for removal under 8 U.S.C. § 1227, as it was deemed a “crime of violence…for which the term of imprisonment [is] at least one year.”
To summarize, the state court sentence was 365 days, while the federal statute required a minimum one-year imprisonment term. Hence, the court was tasked with determining whether 365 days equated to one year under the statute. This confusion led to the case reaching the federal appeals court, which ultimately ruled that 365 days indeed qualified as a year.
Another criminal case, People v. Phillips in 2015, shed light on the relevance of leap years in measuring the passage of time. In this instance, the trial court had omitted two custody credits from the defendant’s sentence, neglecting to consider that the years 2008 and 2012 were leap years. The appeals court rectified this oversight.
Leap Years and “Leapers” in the Legal World
Apart from contractual and sentencing considerations, the legal system also encounters unique challenges when dealing with individuals born on February 29, commonly referred to as “leapers.” One notable query pertains to the legal age of leapers. Do they turn 18 or 21 on February 28 or March 1?
While some states have explicit statutory provisions regarding this issue, not all do. However, determining the applicable date for a specific state is relatively simple by referring to its common law. If a state excludes the day of birth in age computations, then the leaper’s legal age is reached on March 1. Conversely, if the day is included, then February 28 marks the milestone. An American Law Reports article provides a comprehensive state-by-state breakdown.
In conclusion, as seemingly trivial as it may appear, debates and disputes surrounding leap years and leap days persist within the legal landscape. As we approach 2016, another leap year, it is prudent to bear this issue in mind.
Image: Garrity Traina