Commonwealth v. Fassitt

1 Vaux 30
CourtRecorder of Philadelphia
DecidedJuly 1, 1846
StatusPublished

This text of 1 Vaux 30 (Commonwealth v. Fassitt) is published on Counsel Stack Legal Research, covering Recorder of Philadelphia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Fassitt, 1 Vaux 30 (philarec 1846).

Opinion

The Recorder remarked in substance, that the prisoner was arrested on the oath of an unimpeached witness, one w’ho knew officially of the crime with which the prisoner w-as charged. That he had been 'required to execute a warrant for his arrest, and had not found the prisoner in his bailiwick. That he had seen an affidavit made and sworn to, in which an application was made for a requisition. That he had despatched an officer for the requisition, and that it was expected to arrive here in a short time. It is not necessary in order to arrest a fugitive, for such requisition to be produced at the time [32]*32of the arrest, if the oath on which the warrant issues, is sufficient to raise a good reason for believing the party charged has committed a crime in a sister state. The oath is itself sufficient to justify an arrest in all cases; but in cases where the highest crimes are charged, it is not the discretion, but the duty of the magistrate, which should govern his action.

The objects of the Attorney-general and the prisoner’s counsel are the same. Neither desire the surrender of a citizen of this state, into the hands of the officers of another state, until all the forms prescribed by the act of congress are complied with. There is a vast difference, however, between a holding for a farther hearing, at which time, the legal requisition will be made to appear, in due form, and a surrender of the prisoner ■without it.

If the prisoner’s counsel were objecting to the surrender, -under the act of congress, their objection would be sustained; but it is not the wish of the Attorney-general, nor is it my intention, at this stage of the case, to surrender the prisoner into the hands of the officer, to be carried by him to the place where the crime is said to have been committed. It seems to me clear, that my duty is, to hold the prisoner till the legal steps he taken for demanding the surrender. The evidence in this case is sufficiently strong to justify a holding, even if the crime had been committed here. It is the highest order of testimony now to be had, and it would indeed be strange in criminal proceedings, that, a party charged with the highest, crime or any crime, must be discharged at the moment of the arrest, because at that period in the proceedings, there is not evidence enough [33]*33to convict, when still stronger evidence is in existence, but inaccessible at the instant. In cases of fugitives from justice from other states, the ability to obtain all the testimony at the time of the arrest, is almost impossible, and consequently the necessity of holding for a farther hearing, until such witnesses are produced, is most markly manifest.

The act of congress impliedly recognises the arrest of fugitives before a requisition is made. The provisions of the act refer only to such cases, in which the arrest is made after a requisition of one executive on the other, and by virtue of the same.

The section of the act of congress, passed February 12th, 1793, respecting “fugitives from justice,” is in these words:

§ 1. “ Be it enacted, &c., That whenever the executive authority of any state in the union, or of either of the territories north-west or south of the river Ohio, shall demand any person as a fugitive from justice of the executive authority of any such state or territory to which such person shall have fled, and shall moreover produce the copy of an indictment found, or an affidavit made before a magistrate of any state or territory as aforesaid, charging the person so demanded with having committed treason, felony, or other crime, certified as authentic by the governor or chief magistrate of the state or territory from whence the person so charged fled, it shall be the duty of the executive authority of the state or territory to which such person shall have fled, to cause him or her to be arrested and secured, and notice of the arrest to be given to the executive authority making such demand, or to the agent of such [34]*34authority appointed to receive the fugitive, and cause the fugitive to be delivered to such agent when he shall appear: But if no such agent, shall appear within six months from the time of the arrest, the prisoner may be discharged. And all costs or expenses incurred in the apprehension, securing and transmitting such fugitive to the state or territory making such demand, shall be paid by such state or territory.”

The proceedings required to be complied with in this section, are predicated of the fact, that the executive authority of one state has demanded the fugitive from the executive authority of the state into which such fugitive shall have fled, and is then and there sojourning. That in such óase, the forms prescribed by the act of congress must govern the proceedings, admits of no doubt. But the act does not prohibit an arrest of a fugitive under any other circumstances; the law is directory, but not prohibitory.

Congress never intended to pass a law for the furtherance of the ends of justice, which if construed as the prisoner’s counsel construe it now, would prevent the arrest, of any fugitive from a community, the laws of which he had violated.

If a person, after having committed a high crime, such as murder or arson, in New York city, should take his way across the river to New Jersey, he would be there safe, till sufficient time should elapse for a requisition to arrive from Albany at Trenton, and then, to the place of the refuge of such fugitive. And even should the officers of justice seek to detain him, until such demand of the executive authority should, in due form, be made on the [35]*35other, they would be prevented under the construction put upon this act by the prisoner’s counsel.

And again, to show the difficulty of arresting such fugitive. . Suppose a few hours before the arrival of the state agent, with the executive authority to arrest,, the fugitive should, in the very presence of the officers of the state, take his way into another neighbouring state, he would there be safe till the whole proceedings were re-enacted, and so on till such fugitive would be in fact beyond the reach of the law.

Such are the easy and expeditious modes of passing from state to state, that dangerous delay would ensue, before a felon could be arrested, and not before, even then, a demand had been made on perhaps every state executive in the union.

I cannot, believe such was the intention of congress.

The provisions of the act of 1793, apply only to the surrender of a citizen of one state, into the hands of the violated law of another state, for trial; and being directory on that point, it does not, nor never intended, to prohibit an arrest of such offender by the. authority of the state into which he had fled, to await the executive demand of his own, for his surrender for trial.

There is no state or national authority compelling an arrest before an executive demand; but the courtesy due by one state to another, and the long and universal custom regulating arrests in such cases, has made it a right and a duty at common law, thus to aid the states of the union to sustain and carry out their own laws, for their own safety.

As regards the second point, raised by the prisoner’s counsel, the law is equally clear.

[36]*36The warrant issued upon an oath, charging a well defined crime.

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Bluebook (online)
1 Vaux 30, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-fassitt-philarec-1846.