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Carbo v. United States

Citations: 5 L. Ed. 2d 329; 81 S. Ct. 338; 364 U.S. 611; 1961 U.S. LEXIS 1865Docket: 72

Court: Supreme Court of the United States; January 9, 1961; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

This case involves the United States District Court for the Southern District of California's jurisdiction to issue a writ of habeas corpus ad prosequendum, summoning a prisoner from New York City to face trial on extortion and conspiracy charges in California. The petitioner, who had been arrested in Baltimore, contested the writ, arguing that the court lacked the authority to issue it beyond its jurisdiction, referencing 28 U.S.C. § 2241. Both the District Court and the Court of Appeals affirmed the court's jurisdiction, prompting the Supreme Court to review the matter. The Supreme Court concluded that the issuance of the writ was within the court's jurisdiction as authorized by Congress, emphasizing that the writ of habeas corpus ad prosequendum does not have geographical limitations, unlike the Great Writ. Historical context and statutory interpretations were examined, affirming the necessity of such writs for federal and state collaboration in criminal justice. The petitioner's consent to return to California was recognized, reinforcing the court's authority. The ruling clarified that the writ ad prosequendum is distinct from the Great Writ, which is subject to jurisdictional limitations. The decision upheld the procedural propriety of transferring the petitioner for trial, thereby facilitating the prosecution and respecting interstate judicial cooperation.

Legal Issues Addressed

Congressional Authority on Habeas Corpus

Application: Congress has authorized federal courts to issue different types of writs of habeas corpus, including ad prosequendum, without geographical limitations.

Reasoning: Congress had authorized the issuance of writ ad prosequendum by jurisdictions different from where the prisoner was held.

Consent and Jurisdiction

Application: A prisoner's consent to jurisdiction by appearing in court can affirm the court's authority over their case.

Reasoning: His implicit consent to return to California is recognized, affirming that his removal does not undermine the court's authority over his case.

Extraterritorial Issuance of Writs

Application: The writ of habeas corpus ad prosequendum can be issued without territorial restrictions, facilitating federal and state cooperation in criminal justice.

Reasoning: The interpretation suggests that the territorial limitation applies only to the Great Writ, while the writ ad prosequendum retains no geographical restrictions, as evidenced by cases from Circuit Courts of Appeals.

Jurisdiction to Issue Writ of Habeas Corpus ad Prosequendum

Application: The District Court has the authority to issue a writ of habeas corpus ad prosequendum to transfer a prisoner from one state to another for trial.

Reasoning: The United States District Court for the Southern District of California has jurisdiction to issue a writ of habeas corpus ad prosequendum to summon a prisoner from New York City for trial on an indictment in California.

Scope of Habeas Corpus under 28 U.S.C. § 2241

Application: The statute allows for the issuance of writs of habeas corpus under specific custody conditions, including for foreign citizens or those needed for trial.

Reasoning: It clarifies that writs of habeas corpus may be issued by various federal authorities under specific custody conditions outlined in 28 U.S.C. § 2241.