Cuyler v. Adams
Annotate this Case
449 U.S. 433 (1981)
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U.S. Supreme Court
Cuyler v. Adams, 449 U.S. 433 (1981)
Cuyler v. Adams
Argued October 7, 1980
Decided January 21, 1981
449 U.S. 433
While respondent was serving a sentence in a Pennsylvania correctional institution, the Camden County, N.J., prosecutor's office lodged a detainer against him and sought custody pursuant to Art. IV of the Interstate Agreement on Detainers (Detainer Agreement) in order to try him in New Jersey on criminal charges. Article IV, which provides the procedure whereby the receiving State may initiate the prisoner's transfer, states in paragraph (d) that nothing in the Article shall be construed to deprive the prisoner "of any right which he may have to contest the legality of his delivery as provided in paragraph (a) hereof," but that such delivery may not be opposed on the ground that the sending State's executive authority has not affirmatively consented to or ordered the delivery. Respondent filed an action in the Federal District Court for the Eastern District of Pennsylvania under 42 U.S.C. §§ 1981 and 1983, alleging that petitioners had violated the Due Process and Equal Protection Clauses by failing to grant him the pretransfer hearing that would have been available had his transfer been sought under the Uniform Criminal Extradition Act (Extradition Act), and that petitioners had violated the Due Process Clause by failing to inform him of his right under Art. IV (a) of the Detainer Agreement to petition Pennsylvania's Governor to disapprove New Jersey's request for custody. The District Court dismissed respondent's complaint. The Court of Appeals vacated the District Court judgment and remanded the case, finding it unnecessary to reach respondent's constitutional claims and holding as a matter of statutory construction under federal law that respondent had a right under Art. IV (d) of the Detainer Agreement to the procedural safeguards, including a pretransfer hearing, prescribed by the Extradition Act.
1. The Detainer Agreement is a congressionally sanctioned interstate compact the interpretation of which presents a question of federal law. An interstate agreement does not fall within the scope of the Federal Constitution's Compact Clause, and will not be invalidated for lack of congressional consent, where the agreement is not
"directed to the
formation of any combination tending to the increase of political power in the States, which may encroach upon or interfere with the just supremacy of the United States."
But where Congress has authorized the States to enter into a cooperative agreement and the subject matter of that agreement is an appropriate subject for congressional legislation, Congress' consent transforms the States' agreement into federal law under the Compact Clause, and construction of that agreement presents a federal question. Here, Congress gave its consent to the Detainer Agreement in advance by enacting the Crime Control Consent Act of 1934. That Act was intended to be a grant of consent under the Compact Clause, and the subject matter of the Act is an appropriate subject for congressional legislation. Pp. 449 U. S. 438-442.
2. As a matter of statutory construction, a prisoner incarcerated in a jurisdiction that has adopted the Extradition Act is entitled to the procedural protections of that Act, including the right to a pretransfer hearing, before being transferred to another jurisdiction pursuant to Art. IV of the Detainer Agreement. Both the language and legislative history of the Detainer Agreement support the interpretation that, whereas a prisoner initiating the transfer procedure under Art. III waives rights which the sending State affords persons being extradited, including rights provided under the Extradition Act, a prisoner's extradition rights are preserved when the receiving State seeks the prisoner's involuntary transfer under Art. IV of the Detainer Agreement. The phrase "as provided in paragraph (a) hereof," contained in Art. IV (d), modifies "delivery," not "right," and thus Art. IV (d) preserves all the prisoner's extradition rights under state or other law except his right, otherwise available under the Extradition Act, to oppose his transfer on the ground that the sending State's Governor had not explicitly approved the custody request. Moreover, the remedial purpose of the Detainer Agreement in protecting prisoners against whom detainers are outstanding supports an interpretation that gives prisoners the right to a judicial hearing in which they can bring a limited challenge to the receiving State's custody request. Pp. 449 U. S. 443-450.
592 F.2d 720, affirmed.
BRENNAN, J., delivered the opinion of the Court, in which WHITE, MARSHALL, BLACKMUN, POWELL, and STEVENS, JJ., joined. REHNQUIST, J., filed a dissenting opinion, in which BURGER, C.J., and STEWART, J., joined, post, p. 449 U. S. 450.