Aleman v. State, 230 A.3d 97

Pablo Javier Aleman was serving an 11‑year sentence in Ohio when Maryland lodged a detainer charging him with murder.
Aleman invoked the Interstate Agreement on Detainers (IAD) by filing Form II, waiving extradition and consenting to temporary transfer to Maryland to resolve the charge.
Maryland accepted temporary custody and Aleman was transferred; he pled guilty to second‑degree murder but the jury found him "not criminally responsible" (NCR) for the offense.
Maryland trial court indicated it would commit Aleman to the Department of Health under CP §3‑112, but concluded the IAD required return to Ohio before commitment; Aleman filed habeas petitions seeking commitment in Maryland.
The Court of Special Appeals affirmed the denial of relief; the Maryland Court of Appeals granted certiorari to decide (1) whether IAD temporary custody permits a receiving state to commit under CP §3‑112 and (2) whether an NCR verdict removes a prisoner from the IAD via Article VI(b).

Issue	Plaintiff's Argument (Aleman)	Defendant's Argument (State)	Held
Does IAD "temporary custody" give the receiving state jurisdiction to commit a transferred prisoner to state mental‑health custody under CP §3‑112?	Temporary custody includes post‑trial dispositions necessary to resolve the detainer, including commitment for treatment.	IAD custody is strictly limited to prosecution; for all other purposes custody remains with the sending state, so Maryland lacks jurisdiction to commit.	Held: No. Receiving‑state custody under the IAD is temporary and limited to prosecuting charges; Maryland cannot commit Aleman under CP §3‑112 before returning him to Ohio.
Does a verdict of "not criminally responsible" trigger Article VI(b) of the IAD (exempting "any person who is adjudged to be mentally ill") and thus suspend the IAD remedies/return requirement?	An NCR verdict adjudicates mental illness and therefore places the defendant outside the IAD; the compact must yield to commitment and treatment provisions.	Article VI(b) refers to current adjudicated mental illness (e.g., incompetence); an NCR verdict concerns past mental state at time of offense and does not by itself show present mental illness to trigger the exemption.	Held: No. Article VI(b) requires an adjudication of present mental illness; an NCR verdict alone (a finding about past mental state) does not automatically remove a prisoner from IAD coverage.

Carchman v. Nash, 473 U.S. 716 (1985) (discussing problems addressed by the IAD and scope of detainers)
Cuyler v. Adams, 449 U.S. 433 (1981) (treating a congressionally‑sanctioned interstate compact as federal law)
Jones v. United States, 463 U.S. 354 (1983) (holding an insanity acquittal supports an inference of continuing mental illness for commitment statutes)
Simms v. Department of Health, 467 Md. 238 (2020) (Maryland decision addressing commitment and related statutory context)
State v. Beauchene, 541 A.2d 914 (Me. 1988) (Article VI(b) applies to current mental illness at time of transfer request)
State v. King, 733 P.2d 472 (Or. 1987) (Article VI(b) construed as relating to the detainee's condition prior to transfer)