Alabama v. Bozeman | |
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Argued April 17, 2001 Decided June 11, 2001 | |
Full case name | Alabama v. Michael Herman Bozeman |
Citations | 121 S. Ct. 2079; 150 L. Ed. 2d 188; 2001 U.S. LEXIS 4310; 69 U.S.L.W. 4465; 2001 Cal. Daily Op. Service 4735; 2001 Daily Journal DAR 5851; 2001 Colo. J. C.A.R. 2952; 14 Fla. L. Weekly Fed. S 358 |
Prior history | On writ of certiorari to the Supreme Court of Alabama |
Holding | |
The literal language of Article IV(e) of the Interstate Agreement on Detainers bars any further criminal proceedings when a defendant is returned to the original place of imprisonment before trial. | |
Court membership | |
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Case opinions | |
Majority | Breyer, joined by unanimous (parts I, II-A, II-C); Rehnquist, Stevens, O'Connor, Kennedy, Souter, Ginsburg (part II-B) |
Laws applied | |
18 U.S.C. App. §2 |
Alabama v. Bozeman, 533 U.S. 146(2001), was a United States Supreme Court decision involving the prosecution of someone who was already serving a criminal sentence for a different crime in a different state.
The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.
The Supreme Court of the United States is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a small range of cases, such as suits between two or more states, and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The Court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions. Each year it agrees to hear about 100–150 of the more than 7,000 cases that it is asked to review.
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In circumstances where a state wants to get a person for prosecution who is held in another state, they would file a detainer. That is a legal document telling the other state where the person is imprisoned and to produce him for trial later on in the prosecuting state. [1] An interstate compact, which was joined by the Federal Government among almost all other states, set forth procedures as to how this process was to be done. The case concerned a specific provision which says that once the prisoner arrives in the receiving state, he must be tried within 120 days. Otherwise, the case must be dismissed. [2] The federal government sent Michael Bozeman to Alabama to face charges there. After court preliminaries, the next day he was returned to federal prison and then brought back to Alabama for trial. The trial judge rejected a petition to dismiss the charges for a violation of the Interstate Compact and a divided Alabama Supreme Court reversed.
Detainer ; originally in British law, the act of keeping a person against his will, or the wrongful keeping of a person's goods, or other real or personal property. A writ of detainer was a form for the beginning of a personal action against a person already lodged within the walls of a prison; it was superseded by the Judgments Act 1838.
Justice Breyer explained the question as a simple issue of the exact language in the statute. He noted that it says that in circumstances like the present case, the indictment shall not be of any further force and it should be dismissed. Against pleas by Alabama that the question was technical and the violation small, Breyer replied that "[E]ven were we to assume for argument's sake that the Agreement exempts violations that...are de minimis...we could not say that the violation at issue here qualifies as trivial." The decision of the Alabama Supreme Court was affirmed, mandating a dismissal of the indictment against Bozeman in Alabama.
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