Alabama v. Battles
Headline: Extradition paperwork fight: Court denies review and leaves Alabama court’s ruling that Florida’s papers were procedurally inadequate, blocking extradition and creating hurdles for return of the accused.
Holding: The petition for a writ of certiorari was denied; the Supreme Court declined to review and left the Alabama court’s ruling that Florida’s extradition papers were inadequate in place.
- Leaves Alabama court’s block on this extradition in place.
- Signals state procedural rules can prevent governors’ extradition orders.
- Dissent warned this could make it harder to return accused people.
Summary
Background
A man from Alabama was accused by Florida authorities of taking a car in Bay County, Florida, on July 1, 1979, by giving a $1,300 check drawn on a closed Alabama bank account. Florida sent four extradition documents: a verified information dated August 20, 1979 charging two felonies (obtaining a motor vehicle with intent to defraud and passing a worthless check), an affidavit sworn August 31 repeating those facts, an arrest warrant issued under Florida law, and a formal request signed by Florida’s Governor and Secretary of State. Alabama’s Governor ordered rendition and the man was arrested; he admitted many facts at a habeas hearing in Alabama state court.
Reasoning
The Alabama Court of Criminal Appeals reversed the governor’s order, holding Florida’s papers did not satisfy provisions of Alabama law (Ala. Code §§15-9-31 and 15-9-33), requiring a supporting affidavit attached to the information and based on personal knowledge. The Supreme Court denied review. Chief Justice Burger, dissenting, argued the Constitution’s Extradition Clause turns on whether a person is charged and that asylum states may not reweigh the demanding state’s proof, citing Michigan v. Doran and Pacileo v. Walker.
Real world impact
Because the Supreme Court refused to take the case, the Alabama appellate decision remains in effect and, for now, blocks Florida’s attempt to extradite this accused man. The outcome shows that differences between state extradition rules can affect whether a governor’s rendition order will stand. The dissent warned that allowing state-by-state procedural tests could make it harder to return people accused of crimes to the charging state.
Dissents or concurrances
Chief Justice Burger, joined by Justices Blackmun and Rehnquist, would have granted review and summarily reversed, saying Alabama exceeded the narrow, facial review allowed by the Extradition Clause and improperly substituted its own probable-cause view for Florida’s charging decision.
Opinions in this case:
Ask about this case
Ask questions about the entire case, including all opinions (majority, concurrences, dissents).
What was the Court's main decision and reasoning?
How did the dissenting opinions differ from the majority?
What are the practical implications of this ruling?