## Facts

- Puerto Rico charged Ronald Calder, an Iowa resident, with serious felonies including homicide.
- Calder was released on bail in Puerto Rico but failed to appear for a preliminary hearing and was declared a fugitive.
- Puerto Rican officials believed Calder had returned to Iowa; Calder surrendered to Iowa authorities.
- Puerto Rico’s Governor submitted a formal extradition request to Iowa’s Governor.
- After a hearing and unsuccessful intergovernmental negotiations, Iowa’s Governor denied the extradition request.
- Puerto Rico sued in federal court seeking to compel Iowa officials to extradite Calder.

## Issues

1. Whether federal courts have authority to order a state governor to comply with the Extradition Clause and the Extradition Act, 18 U.S.C. § 3182, by honoring a proper extradition demand.
2. Whether prior precedent barring federal courts from compelling a governor to extradite remains controlling.
3. Whether the Extradition Clause and § 3182 impose a mandatory, ministerial duty on the asylum state’s executive, leaving no discretion to deny a valid demand.
4. Whether Puerto Rico may invoke § 3182 to demand extradition from a state.

## Decision

- The Supreme Court unanimously reversed the judgment affirming dismissal and remanded for further proceedings.
- The Court held that federal courts may enforce the Extradition Clause and § 3182 against state governors through appropriate judicial relief.
- The Court overruled prior precedent to the extent it denied federal judicial power to compel a governor to perform the constitutional and statutory extradition duty.
- The Court reaffirmed that the extradition obligation is mandatory and does not permit an asylum-state governor to refuse a proper demand.
- The Court held that Puerto Rico is within § 3182’s coverage and may demand extradition on the same basis as a state under the statute.

## Legal Principles

- The Extradition Clause creates a mandatory duty to deliver up a person charged with a crime who flees and is found in another state upon proper executive demand.
- Congress’s implementing statute, 18 U.S.C. § 3182, likewise imposes a mandatory obligation and applies to states, territories, and districts.
- Federal courts may issue orders compelling state executive officials to comply with federal constitutional and statutory duties, including extradition obligations.
- A governor’s role in honoring a valid extradition demand is ministerial; policy disagreements or dissatisfaction with the charging jurisdiction do not justify refusal.
- Because the extradition duty is imposed by the Constitution itself and implemented by statute, state sovereignty principles do not bar federal judicial enforcement.

## Conclusion

The Court held that a state governor cannot refuse a proper extradition request and that federal courts have authority to compel compliance with the Extradition Clause and 18 U.S.C. § 3182, overruling earlier precedent that had barred such enforcement and confirming Puerto Rico’s ability to seek extradition under the statute.


Puerto Rico v. Branstad, 483 U.S. 219 (1987)