00-492 Alabama v. Bozeman

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“[T]he Agreement makes no distinction among different kinds of IV(c) ‘arrivals,’ say, by exempting those that are followed by return within a short, specified period of time, or those that are simply for the purpose of arraignment. Given the Agreement’s language and the important consequences of starting the running of the 120-day time limit, we see no basis for such a distinction. Hence, we must assume that every prisoner arrival in the receiving State, whether followed by a very brief stay or a very long stay in the receiving State, triggers IV(e)’s ‘no return’ requirement.”

“[W]e cannot say that the one-day violation here is de minimis, technical, or harmless. Neither do the briefs (or, to our knowledge, any lower court opinion) point to any other plausible rehabilitation-related purpose of Article IV(e) specifically, in terms of which the violation here might count as trivial. But we need not decide precisely what led Congress and the many other legislatures to agree to Article IV(e)’s antishuttling remedy. Given the Agreement’s absolute language, it is enough to explain why Alabama’s view of the Agreement’s purpose is not plausible and to point to other purposes more easily squared with Article IV(e)’s text and operation.”

Affirmed.

Local Effect:

The decision overrules the Seventh Circuit’s recognition of a one-day de minimis exception to the IAD in United States v. Roy, 830 F.2d 628 (7th Cir.1987).