Puerto Rico v. Branstad

In 1981, Ronald Calder, an air traffic controller employed by the Federal Aviation Administration in San Juan, Puerto Rico, struck and killed one person and injured another with his vehicle. Calder was arraigned in a district court and charged with first-degree murder and attempted murder. At that time, Calder had been released on $5,000 bail. After Calder failed to appear at a subsequent hearing, his bail was increased to $50,000. Calder again failed to appear at another hearing and, at that time, he was declared to be a fugitive from justice and his bail was increased to $300,000. Puerto Rico officials believed Calder had returned to his family in Iowa and contacted authorities there. Calder subsequently surrendered to police in Polk County, Iowa. Subsequently, the Governor of Puerto Rico (plaintiff) submitted a request for Calder’s extradition to the Governor of Iowa (defendant). After negotiations took place between various members of both Puerto Rico and Iowa, the Iowa Governor denied the request to extradite Calder because the parties could not agree to reduce the charges against Calder. The Commonwealth of Puerto Rico (plaintiff) then filed a complaint in the U.S. District Court for the Southern District of Iowa against Branstad, the Governor of Iowa, seeking a declaration that failure to deliver Calder upon presentation of proper extradition paperwork violated the Extradition Clause and the Extradition Act, 18 U.S.C. § 3182 (the Act). The district court dismissed the complaint, citing the U.S. Supreme Court’s ruling in Kentucky v. Dennison, 16 L.Ed. 717 (1861). The court of appeals affirmed and the U.S. Supreme Court granted certiorari to review.