In the case of Hyatt v. People &C. Ex Rel. Corkran (1902), the United States Supreme Court dealt with issues related to extradition and constitutional law. The petitioner, Thomas J. Hyatt, was charged in New York for forgery but fled to Colorado before he could be tried or convicted in New York courts; therefore, a demand was made by the Governor of New York on the Governor of Colorado for his return under an interstate rendition warrant as per Article IV Section 2 Clause 2 of U.S Constitution which deals with extradition among states. Hyatt challenged this request arguing that since he had not been convicted yet and only charged, it would violate his rights if he were extradited back to New York without due process in Colorado first. The Supreme Court ruled against Hyatt stating that being merely "charged" is sufficient grounds for extradition between states according to federal laws and constitution even if no conviction has occurred yet. This decision reinforced state cooperation in criminal matters and upheld principles behind interstate rendition clause i.e., preventing any state from becoming a safe haven for fugitives fleeing justice from another state.

In the dissenting opinion for Hyatt v. People &C. Ex Rel. Corkran, Justice Harlan argued that the majority's decision was inconsistent with previous rulings and violated principles of federalism by allowing a state to interfere in another state's affairs without its consent. He contended that New York had no jurisdiction over an Illinois corporation unless it voluntarily submitted itself to such jurisdiction or had property within the state which could be attached as part of a legal proceeding. The fact that this corporation did business in New York didn't automatically subject it to local laws, according to him; rather, states should respect each other’s sovereignty under principles of comity and federalism.