Alabama v. Bozeman
In Alabama v. Bozeman, 533 U.S. 146 (2001), the prisoner was serving a federal prison sentence in Florida when an Alabama prosecutor sought to arraign him on firearms charges and have counsel appointed. Bozeman, 533 U.S. at 151.
The prisoner was transferred to Alabama where he spent the night in the county jail. Id.
The next morning he appeared in an Alabama court with local counsel; the prisoner was returned to federal prison that same evening. Id.
When Alabama brought the prisoner back for trial one month later, the prisoner moved to dismiss the state charges because he had been returned to Florida, the original place of imprisonment, prior to trial being had on state charges -- a violation of the Interstate Agreement on Detainers Act (IADA). Id.
The trial court denied the motion to dismiss, the prisoner was convicted on the state charges, and an intermediate Alabama appellate court affirmed the conviction. Id. at 152.
The Alabama State Supreme Court reversed, holding the literal language of the IADA controlled, requiring dismissal of the state charges. Id.
The dissenters on the Alabama Supreme Court argued the violation was merely "technical" and did not require dismissal. Id.
The United States Supreme Court affirmed the Alabama Supreme Court, holding that that language of the IADA:
Militates against an implicit exception for it is absolute. It says that, when a prisoner is "returned" before trial, the indictment, information, or complaint "shall not be of any further force or effect, and the court shall enter an order dismissing the same with prejudice." . The word "shall" is ordinarily "the language of command." Id. at 153.