Moyer v. Nichols

Background

Moyer, a man charged with the murder of Steunenberg, was arrested in Colorado under a warrant issued by that State’s governor and delivered to Idaho authorities. He was indicted in Idaho alongside another defendant and held for trial. Moyer first asked the Idaho Supreme Court to order his release, but that court denied relief. A writ of error to the United States Supreme Court was filed, and after a federal habeas corpus petition was denied by the Circuit Court, Moyer appealed the denial to this Court.

Reasoning

The main question was whether Moyer could be lawfully held for trial after his arrest in Colorado and transfer to Idaho. The Supreme Court explained this case did not differ in principle or fact from an immediately preceding case, Pettibone v. Nichols, and therefore applied the same reasoning. For those reasons, the Court affirmed the lower federal court’s refusal to free Moyer and let Idaho’s custody remain in place, meaning the State may proceed toward trial.

Real world impact

Practically, the ruling upholds the authority of a State to keep and try a person who was arrested in another State and handed over, when courts have previously declined to order release. The opinion also ties several related appeals to the same result by following the Pettibone decision. The outcome is final here for these appeals.

Dissents or concurrances

Justice McKenna registered a dissent, signaling disagreement with the majority’s affirmance but the opinion gives no extended dissenting reasoning in this text.