Warmbo v. State

578 P.2d 582, 1978 Alas. LEXIS 507
CourtAlaska Supreme Court
DecidedMay 5, 1978
DocketNo. 3375
StatusPublished
Cited by1 cases

This text of 578 P.2d 582 (Warmbo v. State) is published on Counsel Stack Legal Research, covering Alaska Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Warmbo v. State, 578 P.2d 582, 1978 Alas. LEXIS 507 (Ala. 1978).

Opinion

OPINION

CONNOR, Justice.

This is an extradition matter. Gregory Joe Warmbo, under indictment in Alaska for passing a forged check, asserts that Alaska is without jurisdiction to try him, because extradition proceedings against him in the State of Washington did not comport with Washington law and with due process.

On February 10, 1977, Warmbo was indicted by a state grand jury in Anchorage for passing a forged check for $1,500 and attempting to pass another for $4,200. A bench warrant was issued for his arrest.

Warmbo was arrested in King County, Washington, and arraigned on March 10, 1977, on a fugitive complaint. Scott Smouse, a Seattle attorney, was appointed to represent him.1 No further action was taken, pending the receipt by the Governor of Washington of a demand for extradition by the Governor of Alaska. RCW 10.88.220. On March 18,1977, the Seattle court indefinitely continued the matter pending word from Alaska.

The demand was executed in Juneau on March 18th. Sometime thereafter Deputy Sheriff Howard of King County informed the Seattle judge and prosecutor of the demand, but did not inform Warmbo or his counsel. Warmbo and his counsel learned of Alaska’s demand on March 31st when [584]*584Warmbo appeared in court concerning an attempt by the State of Washington to revoke his probation.

On March 28th the Governor of Washington issued her warrant of arrest based on the Alaska demand. RCW 10.88.260, Uniform Criminal Extradition Act § 7, AS 12.70.060. On April 1st, at what was apparently the court appearance on the Governor’s warrant contemplated by RCW 10.88.-290, Warmbo and his counsel learned of the issuance of the warrant by the Governor of Washington.

Warmbo’s counsel objected. He insisted that (1) his client was entitled to notice between the time the Governor of Washington received the demand and the time she issued her warrant, (2) his client was entitled to a “Governor’s hearing” before an official in the executive branch, at which hearing the alleged fugitive may request on either legal or equitable grounds that the warrant not issue, (3) the failure to give notice was a denial of due process, (4) the Governor should withdraw her warrant, as RCW 10.88.390 permits her to do, and (5) Warmbo should be given time to raise these points in a petition for habeas corpus as permitted by RCW 10.88.290.

The matter was argued by Smouse, Deputy Howard, and the court on Friday afternoon, April 1st. The judge took the matter under advisement over the weekend and calendared it for Monday, April 4th, at 1:30 p. m. The judge assured Warmbo that “nothing will happen to him until Monday, anyhow.”

Also on Friday, without notice to Warm-bo or his counsel, the probation revocation hold was withdrawn. The personnel at the King County jail apparently thought this cleared the way for Warmbo’s return to Alaska, and on Sunday, April 3rd, he was transported to Anchorage, without notice to the court or to his counsel.

On Monday afternoon, when he returned to court, Warmbo’s counsel was advised by Deputy Howard that Warmbo had been returned to Alaska. He argued the matter further until the court dismissed the fugitive proceeding on the ground that it was moot.

Meanwhile, on the afternoon of April 4th, Warmbo was arraigned on the indictment before Judge Ralph Moody in Anchorage. A public defender, who had no prior knowledge of Warmbo or the case, was appointed to represent him and put in a plea of not guilty on his behalf. The events in Seattle were not mentioned in the brief arraignment.

On Friday, April 8th, Warmbo filed an action for habeas corpus. It was heard before Judge Victor D. Carlson on April 13th, and on April 15th he denied the writ in a written opinion. This appeal was taken from that denial. The underlying criminal action has been stayed pending the disposition of this appeal.

A long and almost unbroken line of authority holds that a state has jurisdiction to try a person for a crime if that person is within the state, even if his presence there was obtained by force, fraud, or violation of the laws of this or another state or country. Frisbie v. Collins, 342 U.S. 519, 72 S.Ct. 509, 96 L.Ed. 541 (1952); Mahon v. Justice, 127 U.S. 700,- 8 S.Ct. 1204, 32 L.Ed. 283 (1888); Ker v. Illinois, 119 U.S. 436, 7 S.Ct. 225, 30 L.Ed. 421 (1886); Glasgow v. State, 469 P.2d 682, 684 (Alaska 1970);2 Annot. 28 A.L.R.Fed. 685 (1976).3

[585]*585Warmbo contends that the Frisbie principle is both outdated and wrong, and that it should not be followed. He points out that the scope of due process of law has been enlarged greatly since the Frisbie decision in 1952, citing such cases as Rochin v. California, 342 U.S. 165, 72 S.Ct. 205, 96 L.Ed. 183 (1952), and Mapp v. Ohio, 367 U.S. 643, 81 S.Ct. 1684, 6 L.Ed.2d 1081 (1961). Additionally, he urges that various Alaska cases have recognized increase protections for persons to whom the extradition process is applied. Indeed, as we observed in Wort-ham v. State, 519 P.2d 797, 800 (Alaska 1974),

“[PJersons subjected to extradition proceedings are protected by certain constitutional rights which assure that the extradition power is not applied against them in an oppressive or arbitrary manner.”

In Montague v. Smedley, 557 P.2d 774 (Alaska 1976), we held that the Fourth Amendment forbade Alaska as an asylum state to render up a prisoner absent a showing of probable cause to believe that he had committed a crime in the demanding state. In Kostic v. Smedley, 522 P.2d 535 (Alaska 1974), we held that extradition proceedings in the asylum state must be stayed if the defendant is mentally incapable of understanding the proceedings and aiding his counsel. This followed from the statutory right to the assistance of counsel in extradition proceedings in the asylum state, as well as by analogy to the due process prohibition against trial of a person mentally incapable of understanding or assisting in his defense.

Warmbo relies on two recent decisions of the Supreme Court of Wisconsin which have permitted judicial inquiry in the demanding state into events in the asylum state.

In State ex rel. Lutchin v.

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Bluebook (online)
578 P.2d 582, 1978 Alas. LEXIS 507, Counsel Stack Legal Research, https://law.counselstack.com/opinion/warmbo-v-state-alaska-1978.