Frisbie v. Collins

Background

Shirley Collins, a man serving a life sentence in a Michigan prison for murder, filed a federal habeas corpus petition claiming Michigan officers seized him in Chicago, handcuffed and beat him, and brought him to Michigan for trial. He argued that his trial and conviction violated the Fourteenth Amendment’s due process protections and also violated the Federal Kidnaping Act. The District Court denied relief without a hearing. The Court of Appeals reversed and ordered a hearing, finding that the Kidnaping Act had altered prior law that allowed prosecutions after forcible abductions. The Supreme Court granted review of the important question.

Reasoning

The Court focused on whether being forcibly brought to a state prevents that state from trying and convicting a person. It relied on prior decisions holding that forcible abduction does not defeat a court’s power to try someone, reasoning that due process is satisfied by notice of charges and a fair trial. The Justices said there were no persuasive reasons to overturn those precedents. The Court also concluded the Federal Kidnaping Act does not add a new punishment that bars state prosecution. Although the Court accepted the appeals court’s finding that special circumstances justified prompt federal consideration, it reversed the appeals court on the merits and affirmed the District Court’s denial.

Real world impact

This ruling means states can proceed with criminal trials even when their officers allegedly seized suspects across state lines. Prisoners who claim they were kidnapped by police will have limited ability to avoid state prosecutions based on that claim alone. The opinion notes that Congress could create a different rule, but it has not done so.