Puerto Rico v. Branstad

For more than a century, Kentucky v. Dennison stood as precedent. In 1981, a federally-employed air traffic controller named Ronald Calder struck two people with his car in San Juan, Puerto Rico. A man was injured; his wife and their unborn child were killed. Witnesses testified that the incident took place immediately after an argument between the two men, and that after having struck the two people, Calder backed his car over the woman's prone body several times.

Charged with first-degree murder and attempted murder, Calder fled to his family's home in Iowa. The Puerto Rican authorities notified Iowa that Calder was a fugitive from justice. Calder surrendered himself in Iowa and posted the bond set by that state. When the governor of Puerto Rico requested Calder's extradition, the governor of Iowa held an extradition hearing where Calder's counsel testified that the accused could not, as a white man, receive a fair trial in the Puerto Rican courts. After attempts to negotiate a reduction of charges for Calder failed, Iowa notified Puerto Rico that the request for extradition was denied.

In 1984, the commonwealth of Puerto Rico filed suit against the state of Iowa and its governor, Terry Branstad, in U.S. district court, seeking a writ of mandamus forcing the governor to comply with the Extradition Clause. The district court and the court of appeals both ruled that the Supreme Court's holding in Kentucky v. Dennison prevented an attempt by federal authorities to force compliance with the clause. The Supreme Court then agreed to consider whether the decision in Kentucky v. Dennison still stood.