342 U.S. 519 (1952)
Shirley Collins, serving a life sentence for murder in a Michigan state prison, brought this habeas corpus case in a United States District Court while acting as his own lawyer.1 His petition alleged that while living in Chicago, Michigan officers forcibly seized, handcuffed, blackjacked and took him to Michigan, and he claimed that trial and conviction under such circumstances violated the Due Process Clause of the Fourteenth Amendment and the Federal Kidnaping Act.2
The District Court denied the writ without a hearing on the ground that the state court had power to try respondent regardless of how presence was procured.3 The Court of Appeals, one judge dissenting, reversed and remanded the cause for hearing, holding that the Federal Kidnaping Act had changed the prior rule that a state could constitutionally try and convict a defendant after acquiring jurisdiction by force.4
To review this question the Supreme Court granted certiorari.5 Before the federal habeas proceedings, Collins had filed a petition for a writ of habeas corpus in the Supreme Court of the State of Michigan which was denied on June 22, 1949.6 The state later contended that the District Court should have denied relief because respondent had an available state remedy, though the record shows no appearance of the state in the initial federal proceedings.7
The Court of Appeals found the existence of special circumstances which required prompt federal intervention in this case.8 The trial court, pointing out that the Michigan Supreme Court had previously denied relief, apparently assumed that no further state corrective process was available and decided against respondent on the merits.9
Whether the power of a court to try a person for crime is impaired by the fact that he had been brought within the court’s jurisdiction by reason of a forcible abduction?10
The established rule is that the power of a court to try a person for crime is not impaired by the fact that he had been brought within the court’s jurisdiction by reason of a forcible abduction. This principle finds its foundation in the understanding that due process of law is satisfied when one present in court is convicted of crime after having been fairly apprized of the charges against him. It is also satisfied after a fair trial in accordance with constitutional procedural safeguards. There is nothing in the Constitution that requires a court to permit a guilty person rightfully convicted to escape justice because he was brought to trial against his will.11
No. The facts of the case demonstrate the precise circumstances under which this longstanding rule must be applied. Shirley Collins, serving a life sentence for murder in a Michigan state prison, brought this habeas corpus case in a United States District Court while acting as his own lawyer. His petition alleged that while living in Chicago, Michigan officers forcibly seized, handcuffed, blackjacked and took him to Michigan, and he claimed that trial and conviction under such circumstances violated the Due Process Clause of the Fourteenth Amendment and the Federal Kidnaping Act.
The District Court denied the writ without a hearing on the ground that the state court had power to try respondent regardless of how presence was procured. The Court of Appeals, one judge dissenting, reversed and remanded the cause for hearing, holding that the Federal Kidnaping Act had changed the prior rule that a state could constitutionally try and convict a defendant after acquiring jurisdiction by force.
To review this question the Supreme Court granted certiorari. Before the federal habeas proceedings, Collins had filed a petition for a writ of habeas corpus in the Supreme Court of the State of Michigan which was denied on June 22, 1949. The state later contended that the District Court should have denied relief because respondent had an available state remedy, though the record shows no appearance of the state in the initial federal proceedings.
The Court of Appeals found the existence of special circumstances which required prompt federal intervention in this case. The trial court, pointing out that the Michigan Supreme Court had previously denied relief, apparently assumed that no further state corrective process was available and decided against respondent on the merits. Applying the rule to these facts, the forcible abduction alleged in Collins's petition does not divest the Michigan court of its authority to try him once he was present, because the established facts confirm that he received a fair trial on the murder charge after being apprised of the accusations.12
The power of the Michigan court to try and convict Collins remained intact despite the forcible manner in which he was brought into the state, and the habeas petition therefore fails on this ground.13
Whether the Federal Kidnaping Act changed the rule that a state could constitutionally try and convict a defendant after acquiring jurisdiction by force?14
The Federal Kidnaping Act prescribes in some detail the severe sanctions Congress wanted it to have. Persons who have violated it can be imprisoned for a term of years or for life. Under some circumstances violators can be given the death sentence. The Act cannot fairly be construed so as to add to the list of sanctions detailed a sanction barring a state from prosecuting persons wrongfully brought to it by its officers.15
No. The Court of Appeals had concluded that the Kidnaping Act altered prior doctrine and entitled Collins to relief if he proved the facts alleged. Yet that conclusion cannot stand when measured against the established facts and the text of the statute.16 The facts show that Michigan officers allegedly violated the Act by seizing Collins in Chicago. But the Act itself supplies only the criminal penalties Congress selected.17
Those penalties do not include any prohibition on subsequent state prosecution.18 The established facts further reveal that the Supreme Court assumed without deciding that the officers violated the Act. Yet it still held that the statute supplies no additional civil sanction disabling a state court from trying a defendant it has in custody.19
The Federal Kidnaping Act left the preexisting rule undisturbed, so the Michigan conviction remains valid even if the officers' conduct violated the federal statute.20
Whether the District Court should have denied relief on the ground that respondent had an available state remedy?21
As a general rule federal courts should deny the writ to state prisoners if there is available State corrective process. But this general rule is not rigid and inflexible. District courts may deviate from it and grant relief in special circumstances. Determination of whether such circumstances exist is largely left to the trial courts subject to appropriate review by the courts of appeals.22
No. The established facts show that the Court of Appeals expressly considered the exhaustion question and found special circumstances requiring prompt federal intervention in this particular case.23 Those circumstances were peculiar to the procedural history here, including the prior denial by the Michigan Supreme Court on June 22, 1949, and the absence of any state appearance in the initial federal proceedings.24 The Supreme Court accepted the Court of Appeals' findings on this point, confirming that the District Court properly reached the merits rather than dismissing for failure to exhaust.25
The District Court correctly proceeded to decide the case on the merits because special circumstances justified federal intervention without further resort to state process.26