Michigan v. Doran
Annotate this Case
439 U.S. 282 (1978)
U.S. Supreme Court
Michigan v. Doran, 439 U.S. 282 (1978)
Michigan v. Doran, 439 U.S. 282 (1978)
Argued October 4, 1978
Decided December 18, 1978
439 U.S. 282
After respondent had been arrested in Michigan and charged with receiving and concealing stolen property (a truck driven from Arizona) and Michigan had notified Arizona authorities, Arizona charged respondent with theft, and an Arizona Justice of the Peace issued an arrest warrant reciting, in accordance with Arizona law, that there was "reasonable cause" to believe that respondent had committed the offense. Thereafter, the Governor of Arizona issued a requisition for respondent's extradition accompanied by the arrest warrant, supporting affidavits, and the original complaint; the Governor of Michigan issued an arrest warrant and ordered extradition. Upon being arraigned on the Michigan warrant, respondent petitioned for a writ of habeas corpus, alleging that the extradition warrant was invalid because it did not comply with the Uniform Criminal Extradition Act in effect in Michigan, and the petition was denied. The Michigan Supreme Court reversed the denial of habeas relief and ordered respondent's release on the ground that Arizona had failed to show a factual basis for its finding of probable cause to support its charge, the Arizona judicial finding of "reasonable cause" and the other supporting documents being found deficient in this respect.
Held: Once the Governor of the asylum State has acted on a requisition for extradition based on the demanding State's judicial determination that probable cause existed, no further judicial inquiry may be had on that issue in the asylum State. Pp. 439 U. S. 286-290.
(a) Interstate extradition was intended to be a summary and mandatory executive proceeding derived from the language of the Extradition Clause of the United States Constitution, which requires that a fugitive from justice found in another State be delivered to the State from which he fled on demand of that State's executive authority, and that Clause never contemplated that the asylum State was to conduct the kind of preliminary inquiry traditionally intervening between the initial arrest and trial. P. 439 U. S. 288.
(b) The courts of an asylum State are bound by the Extradition Clause, the implementing federal statute, 18 U.S.C. § 3182, and, where adopted, the Uniform Criminal Extradition Act. Once the asylum State's Governor has granted extradition, such grant being prima facie evidence that the constitutional and statutory requirements have been
met, a court of that State considering release on habeas corpus can do no more than decide whether the extradition documents, on their face, are in order, whether the petitioner has been charged with a crime in the demanding State, whether he is the person named in the extradition request, and whether he is a fugitive. Pp. 439 U. S. 288-289.
(c) The Michigan Supreme Court's holding that the Arizona judicial finding of "reasonable cause" was deficient finds no support in the record read in the light of the Extradition Clause and Arizona law, and overlooks the "conclusory language" in which criminal charges are ordinarily cast. Pp. 439 U. S. 289-290.
401 Mich. 235, 258 N.W.2d 406, reversed and remanded.
BURGER, C.J., delivered the opinion of the Court, in which STEWART, WHITE, POWELL, REHNQUIST, and STEVENS, JJ., joined. BLACKMUN, J., filed an opinion concurring in the result, in which BRENNAN and MARSHALL, JJ., joined, post, p. 439 U. S. 290.
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