This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The case involves a prisoner who was serving a sentence in New Mexico and was subject to a detainer issued by Arizona for pending charges. The prisoner declined to sign forms to request a final disposition of the Arizona charges under the Interstate Agreement on Detainers (IAD). He later filed a petition for habeas corpus, alleging that Arizona violated the IAD's speedy trial provisions by failing to act on the detainer. The prisoner sought to have the detainer quashed and to receive good-time credit on his sentence.
Procedural History
- District Court, August 3, 1992: The court ruled that the prisoner's habeas corpus petition constituted a request for disposition of the detainer under the IAD and ordered Arizona to take custody of the prisoner within two weeks. A subsequent motion to reconsider was denied.
- District Court, February 5, 1993: The court extended Arizona's deadline to take custody of the prisoner to 180 days, but the order was entered after the period had expired.
- District Court, March 1993: The court quashed the detainer, finding that Arizona failed to act within the 180-day period, and declared the prisoner eligible for parole without the detainer as a condition.
- District Court, August 4, 1993: The court awarded the prisoner good-time credit, found that he had completed his sentence with the credit applied, and ordered his release.
Parties' Submissions
- Appellant (Warden): Argued that the prisoner failed to properly invoke the IAD's provisions for a speedy disposition of the detainer and that the detainer remained valid. Contended that the prisoner was not entitled to good-time credit.
- Appellee (Prisoner): Claimed that Arizona violated the IAD by failing to act on the detainer within the required time frame. Argued that the detainer was invalid and that he was entitled to good-time credit for the period he refused to comply with the detainer.
Legal Issues
- Did the prisoner properly invoke the IAD's provisions for a speedy disposition of the detainer?
- Was the detainer invalid due to Arizona's failure to act within the IAD's time limits?
- Was the prisoner entitled to good-time credit for the period he refused to comply with the detainer?
Disposition
- The Supreme Court of New Mexico reversed the lower court's orders quashing the detainer and awarding good-time credit.
- The case was remanded to the trial court with instructions to reinstate the detainer and the balance of the prisoner's sentence.
Reasons
Per Franchini J. (Frost and Minzner JJ. concurring):
The court found that the prisoner failed to properly invoke the IAD's provisions. To activate the IAD, a prisoner must provide written notice and a request for final disposition to the custodial official, which the prisoner did not do. The habeas corpus petition filed by the prisoner did not constitute a clear, specific, and unambiguous request for final disposition under the IAD.
The court also held that Arizona's inaction did not trigger the IAD's 180-day time limit because the prisoner did not meet the requirements to activate the IAD. The trial court erred in ruling that the prisoner was denied a speedy disposition of the detainer.
Finally, the court determined that the detainer was valid and that the prisoner was not entitled to good-time credit based on his refusal to comply with the detainer. The trial court's rulings on good-time credit and the prisoner's release were reversed.