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Keywords

appealtrialhabeas corpuscomplianceprobationprobation violation
jurisdictionappealprobationrespondentprobation violation

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Carchman v. Nash, 473 U.S. 716, 105 S.Ct. 3401, 87 L.Ed.2d 516, 53 USLW 5097

Facts

Richard Nash was convicted in New Jersey and sentenced to prison, followed by probation. While on probation, he was convicted of new offenses in Pennsylvania, leading New Jersey to issue a detainer for probation violation. Nash requested a final disposition of the probation-violation charge, but New Jersey did not bring him to trial within the required 180 days. After exhausting state remedies, he filed a habeas corpus petition, which was granted by the District Court and affirmed by the Court of Appeals.

Respondent was convicted on criminal charges in New Jersey Superior Court, which imposed prison sentences and a 2-year term of probation to follow imprisonment. Thereafter, while on probation, respondent was charged with criminal offenses in Pennsylvania and was convicted and sentenced to prison there.

Issue

Does Article III of the Interstate Agreement on Detainers apply to detainers based on probation-violation charges?

Must detainers based on outstanding charges of probation violation be disposed of within the terms of the Interstate Agreement on Detainers when such disposition is requested?

Rule

Article III of the Interstate Agreement on Detainers applies only to detainers based on untried criminal charges, specifically indictments, informations, or complaints.

Article III of the Interstate Agreement on Detainers gives a prisoner incarcerated in one State the right to demand the speedy disposition of 'any untried indictment, information or complaint' that is the basis of a detainer lodged against him by another State.

Analysis

The Court analyzed the language of the Agreement, determining that the terms 'indictment,' 'information,' and 'complaint' refer specifically to documents that initiate criminal prosecutions. Since a probation-violation charge does not initiate a new prosecution but rather addresses compliance with probation conditions, it does not fall under the purview of Article III. The Court also considered legislative history and the purposes of the Agreement, concluding that these do not support extending Article III to probation-violation detainers.

The language of Art. III therefore makes clear that the phrase 'untried indictment, information or complaint' in Art. III refers to criminal charges pending against a prisoner.

Conclusion

The Supreme Court reversed the decision of the Court of Appeals, holding that Article III does not apply to detainers based on probation-violation charges.

Accordingly, the judgment of the Court of Appeals is reversed.

Who won?

The State of New Jersey prevailed in the case because the Supreme Court found that the Interstate Agreement on Detainers does not cover probation-violation detainers.

The Court noted in United States v. Mauro, 436 U.S., at 359, 98 S.Ct., at 1846, and in Cuyler v. Adams, 449 U.S., at 436, n. 3, 101 S.Ct., at 706, n. 3, that the House and Senate Reports on the Agreement explain: 'A detainer is a notification filed with the institution in which a prisoner is serving a sentence, advising that he is wanted to face pending criminal charges in another jurisdiction.'

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