Pettibone v. Nichols

Summary

The Supreme Court considered whether a person held in Idaho after being brought from Colorado through alleged fraud and improper extradition procedures was entitled to discharge on federal habeas corpus. The Court held that the methods used to bring the accused into Idaho did not create a federal constitutional or statutory exemption from prosecution there, and affirmed the lower court's judgment. The opinion applied principles from Ker v. Illinois and Mahon v. Justice concerning unlawful removal across state lines.

Holdings

1. Except in an emergency demanding prompt action, a federal court ordinarily should leave a person held by a state for trial to stand trial in the state court, which is presumed able to enforce federal constitutional rights.
2. A person held in actual state custody for trial under a valid state indictment is not entitled to federal habeas release merely because the state allegedly used fraud, conspiracy, unlawful violence, or improper extradition procedures to obtain custody.
3. The Constitution and laws of the United States did not require Idaho's agent to time Pettibone's arrest and removal from Colorado so as to provide a convenient opportunity to seek judicial review there before transportation to Idaho.

Questions Presented

1. Whether a federal court should grant habeas corpus to release a person held by state authorities for trial when the person alleges that state officials fraudulently or unlawfully procured his removal from another state.
2. Whether the methods by which Idaho obtained custody of Pettibone, including alleged fraud, conspiracy, and denial of an opportunity to challenge extradition in Colorado, rendered his detention in Idaho unlawful under the Constitution or laws of the United States.
3. Whether a federal court must permit a person held under a state indictment to litigate in federal habeas corpus whether he was actually a fugitive from the demanding state.

Disposition

affirmed