Friday, November 15, 2013

Hyatt v. People ex rel. Corkran case brief

Hyatt v. People ex rel. Corkran case brief summary
188 U.S. 691 (1903)


CASE SYNOPSIS
Plaintiff in error sheriff sought review of an order from the Court of Appeals of the State of New York, which reversed the dismissal of defendant in error's habeas corpus petition.

CASE FACTS
The governor of New York, acting pursuant to U.S. Rev. Stat. § 5278, issued a warrant for defendant in error's arrest and eventual extradition to Tennessee. Defendant had been charged in Tennessee with larceny and false pretenses. The trial court dismissed defendant in error's habeas corpus petition, but on appeal, the appellate court reversed the trial court.

DISCUSSION

  • On further review, the court upheld the trial court's judgment. 
  • The court held that defendant in error's claim that he was absent from Tennessee when the crimes occurred was uncontradicted. 
  • The court further held that mere constructive presence in the demanding state was not sufficient for extradition under § 5278. 
  • The court also held that because the jurisdictional prerequisite of presence in the demanding state at the time of the offense was lacking, defendant in error was entitled to be discharged.

CONCLUSION
The court affirmed the appellate court's judgment, which reversed the dismissal of defendant in error's habeas corpus petition.

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