Ex Parte Antwaun Deon Robinson, 04-14-00512-CR

Robinson, convicted in Alabama of theft and placed on probation, was alleged to have violated probation and fled to Texas; Alabama sought his extradition.
Alabama submitted extradition paperwork including a governor’s request, arrest warrant for probation violation, indictment, judgment of conviction, probation order, probation officer’s report, a certified Alabama driver’s license copy with photo, and a certification by the Coffee County clerk.
The Texas governor issued a governor’s warrant directing Robinson’s arrest and delivery to Alabama; Robinson filed a habeas application contesting extradition.
At the extradition hearing Texas admitted the Alabama packet and Robinson’s Texas driver’s license (both with photos) into evidence; Robinson argued the documents failed statutory requirements and did not prove his identity.
The trial court denied habeas relief and ordered extradition; Robinson appealed, arguing (1) statutory noncompliance with the Uniform Criminal Extradition Act and (2) insufficient proof of identity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Alabama’s rendition papers complied with the Uniform Criminal Extradition Act	Robinson: Papers invalid because they lacked fingerprints and a certified mugshot and had mismatched case numbers	State (Texas/asylum): Packet included the governor’s warrant, indictment/judgment, probation documents, certified copies, and an Alabama driver’s license with photo; police case number differs from court cause number but does not invalidate documents	Court: Papers complied with art. 51.13 §3; fingerprints/mugshot not required and differing police case number did not render documents facially invalid
Whether the State proved Robinson is the person named in the extradition request	Robinson: Two people share the same name; absence of fingerprint/mugshot means identity not established	State: Introduced certified Alabama driver’s license with photo, Texas driver’s license with photo, and the court could compare the person in court to the documents	Court: Once identity was placed in issue burden shifted to demanding state; photographic ID plus in-court comparison satisfied the burden and proved identity

Michigan v. Doran, 439 U.S. 282 (limitation on asylum-state review in extradition proceedings)
Cal. v. Super. Ct. of Cal., 482 U.S. 400 (asylum-state judicial review limited to specified matters)
Ex parte Walker, 350 S.W.3d 417 (habeas is proper means to test governor’s extradition warrant)
Ex parte Martinez, 530 S.W.2d 578 (strict evidentiary rules not required; identity need not be proved beyond a reasonable doubt)
Ex parte Nelson, 594 S.W.2d 67 (photographic evidence may suffice to establish identity in extradition)
Ex parte Smith, 36 S.W.3d 927 (when identity is contested burden shifts to demanding state)