Carchman v. Nash
1985 U.S. LEXIS 131, 105 S. Ct. 3401, 87 L.Ed.2d 516 (1985)
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Rule of Law:
A detainer based on a probation-violation charge is not a detainer based on an 'untried indictment, information or complaint' within the meaning of Article III of the Interstate Agreement on Detainers (IAD). Therefore, the speedy disposition provisions of the IAD do not apply to such detainers.
Facts:
- In 1976, Richard Nash pleaded guilty to charges in New Jersey and was sentenced to prison followed by a two-year term of probation.
- While on probation in 1978, Nash was arrested in Pennsylvania and charged with several new offenses, including burglary.
- Upon learning of the Pennsylvania arrest, the Mercer County Probation Department in New Jersey notified the New Jersey Superior Court that Nash had violated his probation.
- At the Probation Department's request, the New Jersey court issued a bench warrant for Nash's arrest.
- This warrant was lodged as a detainer with the Pennsylvania corrections officials where Nash was incarcerated following his conviction on the Pennsylvania charges.
- Beginning in April 1979, Nash sent a series of letters to New Jersey officials requesting a final disposition of the probation-violation charge, invoking the IAD.
- New Jersey officials failed to bring Nash to a hearing on the probation-violation charge within 180 days of his request.
Procedural Posture:
- Richard Nash filed a petition for a writ of habeas corpus in the United States District Court for the Middle District of Pennsylvania.
- The case was transferred to the United States District Court for the District of New Jersey, which stayed the action pending exhaustion of state remedies.
- Nash unsuccessfully sought relief in the New Jersey state courts, with the New Jersey Superior Court denying his motion, the Appellate Division affirming, and the New Jersey Supreme Court denying certification.
- Nash returned to the U.S. District Court for the District of New Jersey, which granted his petition for a writ of habeas corpus, holding that the IAD applied and vacating his probation revocation.
- Philip S. Carchman, the Mercer County prosecutor, appealed the District Court's decision to the United States Court of Appeals for the Third Circuit.
- The Third Circuit affirmed the District Court's judgment, creating a conflict among federal and state courts.
- The United States Supreme Court granted certiorari to resolve the conflict.
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Issue:
Does a detainer based on an outstanding probation-violation charge constitute a detainer based on an 'untried indictment, information or complaint' under Article III of the Interstate Agreement on Detainers, thereby triggering the Agreement's 180-day speedy disposition requirement?
Opinions:
Majority - Justice Blackmun
No. A detainer based on a probation-violation charge is not a detainer based on an 'untried indictment, information or complaint' and thus does not trigger the speedy disposition provisions of Article III of the Interstate Agreement on Detainers. The court's reasoning is based on a textual and purposive analysis. First, the plain language of 'indictment,' 'information,' and 'complaint' refers to formal documents that initiate a criminal prosecution for an offense, not a post-conviction proceeding. This interpretation is reinforced by the adjective 'untried' and the IAD's requirement that the prisoner be 'brought to trial,' which implies a full criminal proceeding, not a probation revocation hearing where fewer due process rights apply. Second, the purpose of the IAD is to resolve uncertainties caused by detainers based on potentially unsubstantiated criminal charges, which can negatively affect a prisoner's rehabilitation. A probation violation, particularly one based on a new conviction, is not an unsubstantiated charge, and the uncertainty it creates is less severe than that of an untried criminal charge.
Dissenting - Justice Brennan
Yes. A detainer based on a probation-violation charge should be considered a 'complaint' under Article III of the Interstate Agreement on Detainers, and the Agreement should be liberally construed to effectuate its purposes. The majority's 'plain language' argument is overly technical and ignores the IAD's primary goal of resolving uncertainties that obstruct prisoner rehabilitation, a goal equally implicated by probation-violation detainers. Any detainer that could lead to additional incarceration creates uncertainty, regardless of its source. The term 'complaint' is a broad, generic term sufficient to cover probation-violation charges. By excluding a significant category of detainers, the Court vitiates the Agreement's comprehensive purpose and allows states to gain the benefits of lodging a detainer without accepting the corresponding responsibility to provide a speedy disposition.
Analysis:
This decision significantly narrows the scope of the Interstate Agreement on Detainers (IAD), clarifying that its procedural protections do not extend to post-conviction matters like probation or parole violations. By drawing a sharp line between untried criminal charges and probation violations, the Court limits an inmate's ability to compel a speedy resolution for certain types of detainers under this specific federal law. This holding provides clarity for state correctional and judicial systems but removes a tool that prisoners had used to clear their records of pending matters that could adversely affect their conditions of confinement and eligibility for rehabilitative programs. Future legal challenges concerning detainers will now have to distinguish between those based on new charges (covered by the IAD) and those based on post-conviction supervision violations (not covered).
