## Facts

- Shirley Collins, serving a Michigan life sentence for murder, sought federal habeas relief while confined in a Michigan state prison.
- Collins alleged that while living in Chicago, Michigan officers forcibly seized him, used violence, and transported him to Michigan for prosecution.
- He argued that being tried after this abduction violated the Fourteenth Amendment Due Process Clause and the Federal Kidnapping Act, rendering his conviction invalid.
- Michigan courts had denied collateral relief before Collins filed in federal court.

## Issues

1. Whether a state conviction violates the Fourteenth Amendment’s Due Process Clause when the defendant was brought into the state for trial by forcible abduction from another state.
2. Whether the Federal Kidnapping Act bars a state from trying and convicting a defendant whose presence was obtained through an unlawful abduction by state officers.
3. Whether federal habeas relief should be denied for failure to exhaust available state corrective process, absent “special circumstances.”

## Decision

- The Supreme Court reversed the court of appeals and reinstated the denial of habeas relief.
- The Court held that forcible abduction into the forum state does not impair the state court’s power to try the defendant and does not, by itself, violate due process.
- The Court held that the Federal Kidnapping Act creates criminal sanctions for kidnapping but does not add a sanction barring state prosecution or voiding convictions.
- On exhaustion, the Court did not definitively decide whether state remedies were exhausted, accepting for purposes of decision that “special circumstances” could justify prompt federal review, but rejecting Collins’s claim on the merits.

## Legal Principles

- A court’s jurisdiction to try a criminal defendant is not defeated solely because the defendant was brought within the court’s jurisdiction by forcible or illegal abduction (Ker–Frisbie doctrine).
- The Due Process Clause does not require setting aside an otherwise valid conviction merely because the defendant was brought to trial against his will through unlawful seizure.
- The Federal Kidnapping Act provides penalties against kidnappers; it does not, without explicit congressional direction, strip state courts of authority to prosecute defendants wrongfully brought into the state.
- Federal habeas exhaustion is generally required when state corrective process is available, but federal courts may proceed in “special circumstances.”

## Conclusion

The Court reaffirmed that illegal or forcible cross-border abduction by state officers does not itself void a subsequent state conviction, and it ruled that the Federal Kidnapping Act does not bar state prosecution on that basis.


Frisbie v. Collins, 342 U.S. 519 (1952)