Pennsylvania Bureau of Correction v. United States Marshals Service

1985-11-18

Headline: Federal court ruling limits Marshals: District courts cannot order U.S. Marshals to transport state prisoners outside the courthouse for witnesses, leaving states generally responsible unless exceptional security needs are shown.

Holding: The Court held that, absent an express statutory basis or a specific finding of exceptional security needs, a federal district court may not order the U.S. Marshals Service to transport state prisoners to or from state prisons for trial.

Real World Impact:

Leaves states generally responsible for transporting their prisoners to federal court.
Marshals need not transport state prisoners outside courthouse absent exceptional security findings.
Federal courts can order Marshals only in narrow, clearly documented emergencies.

Topics: prisoner transport, federal court procedure, Marshals Service, state responsibility

Summary

Background

A state prisoner, Richard Garland, sued county officials under 42 U.S.C. § 1983 claiming he was beaten and harassed. A federal magistrate issued writs to bring five inmate witnesses, including Garland, from state prisons to a county facility near the federal courthouse and then ordered the U.S. Marshals Service to move them from that county facility to the federal courthouse and guard them during trial. The Marshals objected, and the Third Circuit partly agreed with the Marshals. The Commonwealth asked the Supreme Court to decide who must bear transport and custody duties when the State is not a party.

Reasoning

The Court addressed whether federal courts may force the Marshals to carry state prisoners to and from state prisons for testimony. It found the habeas statute requires writs be directed to the prisoner’s custodian and does not authorize commanding third parties to bear production costs. The Court also held that the All Writs Act cannot be used in ordinary cases to override that limitation. The decision leaves open a narrow exception: in truly exceptional circumstances, like serious security risks with a specific judicial finding, Marshals might be ordered to transport prisoners.

Real world impact

As a practical matter, states will generally remain responsible for moving their inmates to federal proceedings, and Marshals need not transport state prisoners outside the federal courthouse in routine cases. Federal courts may still order Marshals to act in narrow, clearly documented emergencies, but routine cost-sharing cannot be compelled.

Dissents or concurrances

Justice Stevens dissented, arguing historical practice and judicial discretion support ordering Marshals in this case and that the majority unduly narrows courtroom authority.