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OCR: that post facto violations should be founded uodn the categories set forth by Justice Chase By whatever designation given retrospective penal change, if it involves one of the four Calder categories, and is detrimental to the defendant, . it violates the Post Facto Clause. We think the best way ta make sense out of this discussion in the cases to say that by simply Jabelling law "procedural, legislature does not thereby immunize it from scrutiny under the Ex Post Facto Clause Subtle post facto violalions are more permissible than overt ones But the prohibition which may not be evaded one defined Calder categories Collins 110 S.Ct at 2721 [citations The question becomes whether an increase from one to two years ir parole consideration after initial rejection is encompassed in the Catder cat ...