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Keywords

jurisdictionappealextraditionasylumwrit of mandamus
jurisdictionextraditionwrit of mandamus

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State of Ala. ex rel. Governor and Atty. Gen. v. Engler, 85 F.3d 1205, 1996 Fed.App. 0164P

Facts

Phillip Chance was convicted of murder in Alabama and escaped from prison, subsequently living in Michigan for fourteen years under a gubernatorial grant of 'asylum.' Alabama made multiple requests for extradition, which were denied by Michigan governors based on the merits of Chance's case. The district court ruled that Alabama must give full faith and credit to the asylum decision, leading to Alabama's appeal.

Chance has spent the last fourteen years at liberty in Michigan. Alabama, however, has continued to report him as a fugitive on the list of wanted persons kept by the National Criminal Information Center (NCIC).

Issue

Whether the Governor of Michigan could refuse to extradite Phillip Chance based on the merits of his case and whether the federal courts have jurisdiction to enforce extradition.

Whether the Governor of Michigan could refuse to extradite Phillip Chance based on the merits of his case and whether the federal courts have jurisdiction to enforce extradition.

Rule

The Constitution imposes a duty on state governors to extradite fugitives upon proper request, and federal courts have the power to enforce this duty.

The Constitution imposes on the Governor of each state a duty to surrender any fugitive from the justice of another state to that state upon proper request.

Analysis

The court determined that the Governor of Michigan had no legal basis to deny extradition based on the merits of Chance's case. It emphasized that the only valid grounds for refusing extradition were procedural and that the asylum granted by the previous governor was unconstitutional and thus void. The court also rejected the argument that the recent Supreme Court ruling on extradition could not be applied retroactively.

The court determined that the Governor of Michigan had no legal basis to deny extradition based on the merits of Chance's case.

Conclusion

The court reversed the district court's denial of the writ of mandamus and directed that the writ issue, compelling the extradition of Phillip Chance to Alabama.

We therefore REVERSE the district court's denial of the writ of mandamus, and direct that the writ issue.

Who won?

The State of Alabama prevailed in the case because the court found that the Governor of Michigan had a constitutional duty to extradite Chance and could not refuse based on the merits of his case.

The State of Alabama prevailed in the case because the court found that the Governor of Michigan had a constitutional duty to extradite Chance.

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