- Case Summary

University / Undergraduate
Modified: 11th Jun 2001
Wordcount: 502 words
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Legal Case Summary

Summary: Deals with the Interstate Agreement on Detainers and the violation thereof, the case resulted in favor of the respondent.

Facts

The case of Alabama v. Bozeman was brought before the Supreme Court in 2001. The appeal was made by the State of Alabama regarding a federal prisoner, Thomas Edward Bozeman, who was granted an 'anti-shuttling' dismissal of charges. This was granted under the Interstate Agreement on Detainers (IAD), which aims to prevent the movement of a prisoner between the federal and state jurisdictions. Alabama held that such a dismissal violated the IAD clause and thus should not have been granted.

Issues

The primary issue that was to be resolved in the case was whether Article IV (e) of the Interstate Agreement on Detainers, also known as the 'anti-shuttling' provision, applies when a prisoner is returned to the original place of imprisonment on the same day as the trial. The issue of the severity of the violation of the I.A.D. by transferring Bozeman was also under consideration.

Analysis

The ruling in this case emphasized the literal interpretation of the law. This decision clarified the justice procedures for prisoners and how they are not to be excessively transported, thereby respecting their personal rights while caught in jurisdictional procedures. The decision was also significant as it reinforced how strictly the courts adhere to the Interstate Agreement on Detainers.

Decision

The Supreme Court ruled in a 7-2 vote that the dismissal as a result of Alabama's violation of the 'anti-shuttling' provision was valid. Justice Ginsburg, writing for the majority, stated that Alabama's violation of the 'anti-shuttling' provision demanded the dismissal of the indictment, regardless of the length of the move. The judgement stood in favour of Bozeman.

References

  • Alabama v. Bozeman, 533 U.S. 146(2001).
  • Interstate Agreement on Detainers Act.
  • Federal Rules of Criminal Procedure.


Journalist Brief

In the case Alabama v. Bozeman, the US Supreme Court held in favor of Bozeman, a convicted prisoner. Bozeman was repeatedly moved across state lines for the court proceedings of a separate crime. However, a rule exists called the 'anti-shuttling' provision which asserts that prisoners should not be 'shuttled' back and forth excessively across state lines. The court ruled that a violation of this provision had taken place in Bozeman's case. This ruling clarified the legal procedures for dealing with multiple jurisdictions.

FAQs

What is the Interstate Agreement on Detainers?

Answer: It relates to the transfer of prisoners between states in the U.S. and aims to prevent multiple transfers, particularly when a separate crime is involved.

What was the decision of the court in Alabama v. Bozeman?

Answer: The Supreme Court ruled in favor of Bozeman, stating that Alabama violated the 'anti-shuttling' provision.

What is the 'anti-shuttling' provision?

Answer: It’s a rule which states that prisoners should not be shuttled excessively between state and federal jurisdictions for legal proceedings

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