Reed v. Farley

Background

Orrin Scott Reed, then serving in a federal prison, was transferred to Indiana custody under the Interstate Agreement on Detainers so the State could try him on theft and habitual‑offender charges. Two pretrial conferences set trial dates after the agreement’s 120‑day deadline. Reed filed several written motions mentioning the IAD generally but did not clearly object in open court to the scheduled dates until after the 120 days had passed; he later asked for and received a postponement and was tried in October and convicted.

Reasoning

The Court considered whether a state court’s failure to meet the IAD’s 120‑day rule can be raised in a federal habeas petition under 28 U.S.C. §2254. The Court treated the IAD as federal law but applied the established limit on collateral habeas review for statutory errors: relief is available only for fundamental defects. Because Reed did not register a timely objection in open court and did not show prejudice from the delay, the Court concluded §2254 relief was not available and affirmed the lower courts, while leaving open cases where timely, ignored objections exist.

Real world impact

The decision means prisoners transferred between jurisdictions under the IAD must press any 120‑day objection promptly in open court to preserve a federal habeas claim. It also signals that delayed trials without shown prejudice will not generally justify habeas relief, though the Court did not decide every possible fact pattern.

Dissents or concurrances

Justice Blackmun dissented, arguing Congress intended dismissal with prejudice for IAD violations and federal habeas should enforce that remedy; Justice Scalia concurred in the judgment but criticized the majority’s narrow application of the review standard.