Frisbie v. Collins
342 U.S. 519 (1952)
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Rule of Law:
The power of a court to try a person for a crime is not impaired by the fact that the defendant was brought within the court's jurisdiction by reason of a forcible abduction. A defendant's conviction is not voided by the illegality of their arrest or seizure, provided the trial itself is fair and adheres to constitutional due process safeguards.
Facts:
- Shirley Collins was living in Chicago, Illinois.
- Michigan police officers went to Chicago, where they forcibly seized Collins.
- The officers handcuffed and blackjacked Collins.
- The officers then transported Collins from Illinois to Michigan to stand trial for murder.
- Following a trial in a Michigan court, Collins was convicted of murder.
- Collins is serving a life sentence in a Michigan state prison as a result of the conviction.
Procedural Posture:
- After his conviction in a Michigan state court, Shirley Collins filed a petition for a writ of habeas corpus in a U.S. District Court.
- The District Court denied the writ without a hearing.
- Collins, as appellant, appealed the denial to the U.S. Court of Appeals for the Sixth Circuit.
- The Court of Appeals, with one judge dissenting, reversed the District Court's judgment and remanded the case for a hearing.
- Frisbie, the prison warden, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court to review the decision of the Court of Appeals.
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Issue:
Does the forcible abduction of a defendant from one state to another by state officers, in potential violation of the Federal Kidnaping Act, violate the Due Process Clause of the Fourteenth Amendment and deprive the trial court of jurisdiction, thereby nullifying the conviction?
Opinions:
Majority - Mr. Justice Black
No. The forcible abduction of a defendant to bring them into a court's jurisdiction does not violate the Due Process Clause or invalidate a subsequent conviction. The Court reaffirmed its long-standing precedent from Ker v. Illinois, holding that a court's power to try a person for a crime is not undermined by the illegal or forcible means used to bring them before the court. Due process is satisfied when the defendant is present in court, fairly informed of the charges, and receives a fair trial with all constitutional procedural safeguards. The Federal Kidnaping Act provides severe sanctions for its violation, such as imprisonment or the death penalty, but it does not include the sanction of barring a state from prosecuting a person who was wrongfully brought into its jurisdiction. The Court reasoned that it could not add such a sanction to the statute, as that power belongs to Congress.
Analysis:
This case strongly reaffirms the Ker-Frisbie doctrine, which establishes a clear separation between the legality of a defendant's apprehension and the court's jurisdiction to conduct a trial. It clarifies that even a federal criminal statute prohibiting the method of apprehension (the Federal Kidnaping Act) does not create an implicit exclusionary rule for jurisdiction. The decision maintains that the remedy for illegal police conduct like abduction is the prosecution of the offending officers, not the release of a defendant who was otherwise fairly tried and convicted. This precedent has significant implications for international extraditions and irregular renditions, reinforcing the principle that the defendant's presence in court is sufficient for jurisdiction, regardless of how that presence was secured.
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