Alabama v. Bozeman
Encyclopedia
Alabama v. Bozeman, 533 U.S. 146 (2001), was a United States Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...

 case decided in 2001. The case concerned a state that wanted to prosecute a person who was already serving a criminal sentence for a different crime
Extradition
Extradition is the official process whereby one nation or state surrenders a suspected or convicted criminal to another nation or state. Between nation states, extradition is regulated by treaties...

 in a different state.

Background

In circumstances where a state wants to get a person for prosecution who is held in another state, they would file a detainer
Detainer
Detainer ; in law, the act of keeping a person against his will, or the wrongful keeping of a person's goods, or other real or personal property...

. That is a legal document telling the other state where the person is imprisoned and to produce him for trial later on in the prosecuting state. An interstate compact, which was joined by the Federal Government among almost all other states, set forth procedures as to how this process was to be done. The case concerned a specific provision which says that once the prisoner arrives in the receiving state, he must be tried within 120 days. Otherwise, the case must be dismissed. The federal government sent Michael Bozeman to Alabama to face charges there. After court preliminaries, the next day he was returned to federal prison and then brought back to Alabama for trial. The trial judge rejected a petition to dismiss the charges for a violation of the Interstate Compact and a divided Alabama Supreme Court
Alabama Supreme Court
The Supreme Court of Alabama is the highest court in the state of Alabama. The court consists of an elected Chief Justice and eight elected Associate Justices. Each justice is elected in partisan elections for staggered six year terms. The Governor of Alabama may fill vacancies when they occur...

 reversed.

Opinion of the Court

Justice Breyer explained the question as a simple issue of the exact language in the statute. He noted that it says that in circumstances like the present case, the indictment
Indictment
An indictment , in the common-law legal system, is a formal accusation that a person has committed a crime. In jurisdictions that maintain the concept of felonies, the serious criminal offence is a felony; jurisdictions that lack the concept of felonies often use that of an indictable offence—an...

 shall not be of any further force and it should be dismissed. Against pleas by Alabama that the question was technical and the violation small, Breyer replied that "[E]ven were we to assume for argument's sake that the Agreement exempts violations that...are de minimis
De minimis
De minimis is a Latin expression meaning about minimal things, normally in the locutions de minimis non curat praetor or de minimis non curat lex .In risk assessment it refers to a level of risk that is too small to be concerned with...

...we could not say that the violation at issue here qualifies as trivial." The decision of the Alabama Supreme Court was affirmed, mandating a dismissal of the indictment against Bozeman in Alabama.
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