Cuyler v. Adams, No. 78-1841

CourtUnited States Supreme Court
Writing for the CourtBRENNAN
Citation449 U.S. 433,101 S.Ct. 703,66 L.Ed.2d 641
Docket NumberNo. 78-1841
Decision Date21 January 1981
PartiesJulius T. CUYLER, Superintendent, State Correctional Institution, et al., Petitioners, v. John ADAMS

449 U.S. 433
101 S.Ct. 703
66 L.Ed.2d 641
Julius T. CUYLER, Superintendent, State Correctional Institution, et al., Petitioners,

v.

John ADAMS.

No. 78-1841.
Argued Oct. 7, 1980.
Decided Jan. 21, 1981.
Syllabus

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.

Held:

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

Page 434

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. 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. 443-450.

3 Cir., 592 F.2d 720, affirmed.

Maria Parisi Vickers, Philadelphia, Pa., for petitioners.

Page 435

James D. Crawford, Philadelphia, Pa., for respondent.

Justice BRENNAN delivered the opinion of the Court.

This case requires us to decide a recurring question concerning the relationship between the Interstate Agreement on Detainers and the Uniform Criminal Extradition Act.1 The specific issue presented is whether a prisoner incarcerated in a jurisdiction that has adopted the Extradition Act is entitled to the procedural protections of that Act—particularly the right to a pretransfer hearing—before being transferred to another jurisdiction pursuant to Art. IV of the Detainer Agreement. The Court of Appeals for the Third Circuit held as a matter of statutory construction that a prisoner is entitled to such protections. 592 F.2d 720 (1979). The Courts

Page 436

of Appeals and state courts are divided upon the question,2 and we granted certiorari to resolve the conflict. 444 U.S. 1069, 100 S.Ct. 1011, 62 L.Ed.2d 750 (1980).

I

In April 1976, respondent John Adams was convicted in Pennsylvania state court of robbery and was sentenced to 30 years in the State Correctional Institution at Graterford, Pa. The Camden County (New Jersey) prosecutor's office subsequently lodged a detainer against respondent and in May 1977 filed a "Request for Temporary Custody" pursuant to Art. IV of the Detainer Agreement in order to bring him to Camden for trial on charges of armed robbery and other offenses.3

In an effort to prevent his transfer, respondent filed a pro se class-action complaint in June 1977 in the United States District Court for the Eastern District of Pennsylvania. He sought declaratory, injunctive, and monetary relief under 42 U.S.C. §§ 1981 and 1983, alleging (1) that petitioners had violated the Due Process and Equal Protection Clauses by failing to grant him the pretransfer hearing that would have

Page 437

been available had he been transferred pursuant to the Extradition Act; and (2) that petitioners had violated the Due Process Clause by failing to inform him of his right pursuant to Art. IV(a) of the Detainer Agreement to petition Pennsylvania's Governor to disapprove New Jersey's request for custody. Respondent contended, inter alia, that had he been granted a hearing or advised of his right to petition the Governor, he would have been able to convince Pennsylvania authorities to deny the custody request.4

The District Court, without reaching the class certification issue, dismissed respondent's complaint in October 1977 for failure to state a claim upon which relief could be granted, 441 F.Supp. 556. Respondent was then transferred to New Jersey,5 where he was convicted, sentenced to a 91/2-year prison term (to be served concurrently with his Pennsylvania sentence), and returned to Pennsylvania.

The Court of Appeals for the Third Circuit vacated the District Court judgment and remanded for further proceedings. 592 F.2d 720 (1979). Finding no need to reach respondent's constitutional claims, see Hagans v. Lavine, 415 U.S. 528, 543, 94 S.Ct. 1372, 1382, 39 L.Ed.2d 577 (1974), it concluded as a matter of statutory construction that respondent had a right under Art. IV(d) of the Detainer Agreement to the procedural safeguards, including a pretransfer "hearing," prescribed by § 10 of the Extradition Act. It made no finding with respect to respond-

Page 438

ent's argument that he was entitled to notification of his right to petition the Governor.6

II

While this case was on appeal, a Pennsylvania state court held that state prisoners transferred under Art. IV of the Detainer Agreement have no constitutional right to a pretransfer hearing. Commonwealth ex rel. Coleman v. Cuyler, 261 Pa.Super. 274, 396 A.2d 394 (1978). Although the Court of Appeals did not reach this constitutional issue, it held that it was not bound by the state court's result because the Detainer Agreement is an interstate compact approved by Congress and is thus a federal law subject to federal rather than state construction. Before reaching the merits of the Third Circuit's decision, we must determine whether that conclusion was correct. We hold that it was.

The Compact Clause of the United States Constitution, Art. I, § 10, cl. 3, provides that "No State shall, without the Consent of the Congress, . . . enter into any Agreement or Compact with another State . . . ." Because congressional consent transforms an interstate compact within this Clause into a law of the United States, we have held that the construction of an interstate agreement sanctioned by Congress under the Compact Clause presents a federal question. See Petty v. Tennessee-Missouri Bridge Comm'n, 359 U.S. 275, 278, 79 S.Ct. 785, 788, 3 L.Ed.2d 804 (1959); West Virginia ex rel. Dyer v. Sims, 341 U.S. 22, 28, 71 S.Ct. 557, 560, 95 L.Ed. 713 (1951); Delaware River Joint Toll Bridge Comm'n v. Colburn, 310 U.S. 419, 427, 60 S.Ct. 1039, 1040, 84 L.Ed. 1287 (1940).7 It thus remains to be

Page 439

determined whether the Detainer Agreement is a congressionally sanctioned interstate compact within Art I, § 10, of the Constitution.

The requirement of congressional consent is at the heart of the Compact Clause. By vesting in Congress the power to grant or...

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586 practice notes
  • Bimber's Delwood, Inc. v. James, 20-CV-1043S
    • United States
    • United States District Courts. 2nd Circuit. United States District Court of Western District of New York
    • October 21, 2020
    ...power over cooperative state action that might otherwise interfere with the full and free exercise of federal authority." Cuyler v. Adams, 449 U.S. 433, 440, 101 S. Ct. 703, 66 L. Ed. 2d 641 (1981). But not all interstate agreements fall under the Compact Clause. Where an interstate agreeme......
  • Vibo Corp., Inc. v. Conway, No. 08-571-C.
    • United States
    • United States District Courts. 6th Circuit. United States District Court of Western District of Kentucky
    • January 5, 2009
    ...3. "Congressional consent is not required for interstate agreements that fall outside the scope of the Compact Clause." Cuyler v. Adams, 449 U.S. 433, 440, 101 S.Ct. 703, 66 L.Ed.2d 641 (1981). This clause applies only to "any combination tending to the increase of political power in the st......
  • Parks v. Bourbeau
    • United States
    • Supreme Court of Connecticut
    • May 29, 1984
    ...(c) whether the plaintiff is the person named in the request for extradition and (d) whether the plaintiff is a fugitive. Cuyler v. Adams, 449 U.S. 433, 443 n. 11, 101 S.Ct. 703 [709 n. 11], 66 L.Ed.2d 641 (1981); Michigan v. Doran, 439 U.S. 282, 289, 99 S.Ct. 530 , 58 L.Ed.2d 521 (1978).' ......
  • Kerpen v. Metro. Wash. Airports Auth., 1:16cv1307 (JCC/TCB)
    • United States
    • United States District Courts. 4th Circuit. United States District Court (Eastern District of Virginia)
    • May 30, 2017
    ...over cooperative state action that might otherwise interfere with the full and free exercise of federal authority." Cuyler v. Adams , 449 U.S. 433, 439–40, 101 S.Ct. 703, 66 L.Ed.2d 641 (1981). Where an agreement between states would tend to " ‘increase [the] political power in 260 F.Supp.3......
  • Request a trial to view additional results
585 cases
  • Bimber's Delwood, Inc. v. James, 20-CV-1043S
    • United States
    • United States District Courts. 2nd Circuit. United States District Court of Western District of New York
    • October 21, 2020
    ...power over cooperative state action that might otherwise interfere with the full and free exercise of federal authority." Cuyler v. Adams, 449 U.S. 433, 440, 101 S. Ct. 703, 66 L. Ed. 2d 641 (1981). But not all interstate agreements fall under the Compact Clause. Where an interstate agreeme......
  • Vibo Corp., Inc. v. Conway, No. 08-571-C.
    • United States
    • United States District Courts. 6th Circuit. United States District Court of Western District of Kentucky
    • January 5, 2009
    ...3. "Congressional consent is not required for interstate agreements that fall outside the scope of the Compact Clause." Cuyler v. Adams, 449 U.S. 433, 440, 101 S.Ct. 703, 66 L.Ed.2d 641 (1981). This clause applies only to "any combination tending to the increase of political power in the st......
  • Parks v. Bourbeau
    • United States
    • Supreme Court of Connecticut
    • May 29, 1984
    ...(c) whether the plaintiff is the person named in the request for extradition and (d) whether the plaintiff is a fugitive. Cuyler v. Adams, 449 U.S. 433, 443 n. 11, 101 S.Ct. 703 [709 n. 11], 66 L.Ed.2d 641 (1981); Michigan v. Doran, 439 U.S. 282, 289, 99 S.Ct. 530 , 58 L.Ed.2d 521 (1978).' ......
  • Kerpen v. Metro. Wash. Airports Auth., 1:16cv1307 (JCC/TCB)
    • United States
    • United States District Courts. 4th Circuit. United States District Court (Eastern District of Virginia)
    • May 30, 2017
    ...over cooperative state action that might otherwise interfere with the full and free exercise of federal authority." Cuyler v. Adams , 449 U.S. 433, 439–40, 101 S.Ct. 703, 66 L.Ed.2d 641 (1981). Where an agreement between states would tend to " ‘increase [the] political power in 260 F.Supp.3......
  • Request a trial to view additional results
1 books & journal articles
  • Rethinking the Supreme Court’s Interstate Waters Jurisprudence
    • United States
    • Georgetown Environmental Law Review Nbr. 33-2, January 2021
    • January 1, 2021
    ...125 U.S. 1, 15–17 (1888); Missouri v. Illinois, 180 U.S. 208, 227 (1900); Missouri v. Illinois, 200 U.S. 496, 518 (1906); Cuyler v. Adams, 449 U.S. 433, 438–39, 438 n.7 (1981). 61. See Monroe, supra note 30, at 30–38, 70–71. 62. See e.g., South Carolina, 93 U.S. at 5; Wisconsin v. Duluth, 9......

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