State of Tennessee v. Michael Shane Springer

In this appeal, we interpret the meaning of the phrase “term of imprisonment” in Articles III and IV of the Interstate Agreement on Detainers (“IAD”), Tenn. Code Ann. §§ 40-31-101 to -108 (2006), and determine whether the defendant is entitled to relief under the IAD. The IAD, a compact between state and federal jurisdictions, provides cooperative procedures for the exchange of prisoners between state and federal jurisdictions so that prisoners can be brought to trial on untried indictments or complaints. Under Article III of the IAD, a prisoner serving a term of imprisonment may request a trial within 180 days after being delivered to another state. Under Article IV of the IAD, an official of one jurisdiction may seek custody of a prisoner serving a term of imprisonment in another jurisdiction, but the prisoner must be tried within 120 days of arrival in that jurisdiction and cannot be “shuttled” back to the original place of imprisonment before the trial. The IAD mandates a dismissal of the indictment for a violation of either Article III or IV. The defendant in this case was arrested on related federal and state charges and taken into federal custody. After the defendant was tried and convicted in federal court, he was indicted by the grand jury in Gibson County on the related state charges. Before being sentenced in federal court, the defendant filed a demand for speedy disposition of the state charges under Article III of the IAD. While the defendant was confined at a federal temporary detention facility after his sentencing in federal court, the Gibson County Sheriff filed a detainer and transported the defendant to Gibson County for an arraignment. After counsel was appointed and the defendant was arraigned, he was transferred back into federal custody. The defendant filed a motion to dismiss the state indictment for violations of Articles III and IV of the IAD. The trial court denied the motion. The defendant entered a conditional guilty plea pursuant to Tenn. R. Crim. P. 11 and reserved a certified question of law seeking appellate review of the denial of the motion to dismiss because of the alleged violation of the IAD. The Court of Criminal Appeals, in a divided opinion, affirmed the trial court’s denial of the defendant’s motion to dismiss. See State v. Springer, No. W2010-02153-CCA-R3-CD, 2012 WL 603820, at *1 (Tenn. Crim. App. Feb. 16, 2012). We hold that for purposes of the IAD, a prisoner who is incarcerated after sentencing is serving a “term of imprisonment.” We further hold that the defendant properly reserved his issues for appeal in the certified question; that the defendant was a federal pretrial detainee at the time he filed a procedurally deficient demand for speedy disposition and is not entitled to relief under Article III; and that the defendant was serving a term of imprisonment when he was transferred, pursuant to a detainer, from the federal temporary detention facility to Gibson County for his arraignment and back to federal custody on the same day. Article IV of the IAD was violated when the defendant was transferred back to the federal detention center before being tried for the state charges. The judgment of the Court of Criminal Appeals is reversed, the conviction is vacated, and the indictment against the defendant is dismissed with prejudice.