Supreme Court Rules that Federal Law Requires Dismissal of State Charges

June 24, 2013

The Tennessee Supreme Court ruled today that state criminal charges pending against Michael Shane Springer must be dismissed based on his multiple transfers between federal and state correctional facilities, a violation of the Interstate Agreement on Detainers (IAD).

The IAD is an agreement among the federal government and 48 states, including Tennessee, which provides cooperative procedures for the exchange of prisoners between state and federal jurisdictions so that the prisoners can be brought to trial on untried indictments or complaints.

The IAD in part seeks to minimize the disruption of prisoner rehabilitation programs by prohibiting the shuttling of prisoners between jurisdictions to address outstanding charges. Violations of the anti-shuttling provisions of the IAD mandate dismissal of the pending criminal charges.

Mr. Springer was arrested on federal and state charges and was taken into federal custody in August 2006. He was tried and convicted in federal court. Before he was sentenced in federal court to a 20-year prison sentence, a Gibson County grand jury indicted him for the state charges.

After he was sentenced and returned to a federal detention facility, the Gibson County sheriff lodged a detainer – a request regarding custody of one who is incarcerated –­ against Mr. Springer. Pursuant to the detainer, Mr. Springer was transferred from federal custody to state custody for pretrial proceedings and then back into federal custody before he was tried on the state charges.

In the unanimous opinion, the Tennessee Supreme Court held that because Mr. Springer had been transferred pursuant to a detainer from federal custody to state custody and back to federal custody before he was tried on the state charges, the terms of the IAD were violated and federal law, as interpreted by the Supreme Court of the United States, required dismissal of the state charges.

Accordingly, the Tennessee Supreme Court dismissed the state indictment against Mr. Springer and thereby reversed the judgment of the trial court and the Court of Criminal Appeals. Mr. Springer remains in federal custody serving a 20-year sentence for the federal conviction.

Read the State of Tennessee v. Michael Shane Springer Opinion, authored by Justice Sharon G. Lee.