Puerto Rico v. Branstad case brief

Puerto Rico v. Branstad case brief summary
483 U.S. 219 (1987)

CASE SYNOPSIS

Petitioner Commonwealth sought review of a decision by the United States Court of Appeals for the Eighth Circuit, which denied its request seeking a declaration under the Extradition Clause and the Extradition Act, 18 U.S.C.S. § 3182. The circuit court had agreed that prior caselaw barred any attempt to invoke federal judicial authority to compel compliance with the Clause or the Act.

CASE FACTS
A Commonwealth challenged the decision of a circuit court that affirmed a lower court decision denying the Commonwealth its request for a declaration ordering the governor to fulfill the State's obligation under the Extradition Clause of the Constitution, U.S. Const. art. IV, § 2, to deliver up fugitives from justice. The circuit court "reluctantly" affirmed the decision based upon prior caselaw that absolutely barred any attempt to invoke federal judicial authority to compel compliance with the Clause or the Act.

DISCUSSION

• The court reversed the judgment, finding that the prior case law no longer applied. 
• The court found that the Act applied to the Commonwealth and that the Commonwealth could invoke the power of federal courts to enforce against state officers rights created by federal statutes, including equitable relief to compel performance of federal statutory duties. 
• The court held that the commands of the Extradition Clause were mandatory, and afforded no discretion to the executive officers or courts of the asylum state.

CONCLUSION
The Court reversed the judgment finding that prior caselaw barred the invocation of federal judiciary authority under the Act. The Court overruled a prior holding that federal courts had no power to order the governor of a state to fulfill the state's obligation under the Extradition Clause of the Constitution, to deliver up fugitives from justice.

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