Swanigan v. United States Book Reviews

Swanigan v. United States by District of Columbia Court of Appeals. Book Summary

Submitted February 26, 2004 While he was serving a prison sentence in Virginia, appellant Michael Swanigan made a request under Article III of the Interstate Agreement on Detainers (IAD) for a final disposition of charges that were pending against him in Superior Court of the District of Columbia. When, despite his request, Swanigan was not brought to trial within the 180-day period specified by the IAD, he moved to dismiss his indictment in this jurisdiction with prejudice. The trial court denied the motion, concluding that the IAD did not apply to Swanigan's case because he had finished serving his sentence in Virginia before he was returned to the District of Columbia for trial. The sole issue presented by this appeal is whether that ruling was correct. We affirm the trial court's decision. The IAD did not require that Swanigan be brought to trial in the District of Columbia within 180 days of his request, we hold, because Swanigan finished serving his Virginia prison sentence before the 180-day period expired.

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