As a general principle, convicted persons enjoy no right to interstate travel or a constitutionally protected interest to supervision in another state. Federal and state courts have grounded this proposition in limitations in the right to travel outside the sentencing jurisdiction, public safety priorities, and correctional resource management. Federal cases discussing this principle include: Morrissey v. Brewer, 408 U.S. 471, 478, 480 (1972) (“conditions [of parole] restrict [a parolee’s] activities substantially beyond the ordinary restrictions imposed by law on an individual citizen”; parolees do not enjoy “the absolute liberty to which every citizen is entitled, but only . . . conditional liberty properly dependent on observance of special parole restrictions”). Jones v. Helms, 452 U.S. 412, 418-20 (1981) (a person who has committed an offense punishable by imprisonment does not have an unqualified right to leave the jurisdiction prior to arrest or conviction); Griffin v. Wisconsin, 483 U.S. 868, 874 (1987) (following Morrissey); U.S. v. Knights, 534 U.S. 112, 119 (2001) (“Just as other punishments for criminal convictions curtail an offender’s freedoms, a court granting probation may impose reasonable conditions that deprive the individual of some freedoms enjoyed by law-abiding citizens.”); Wilkinson v. Austin, 545 U.S. 209, 228-30 (2005) (inmates may have protected due process interests, but state’s interests in public safety and management of scarce resources are dominant considerations owed great deference). See also Hyser v. Reed, 318 F.2d 225, 239 (D.C. Cir. 1963) (en banc) (while paroled, the supervised individual is a convicted person who is being “field tested” toward rehabilitation; therefore, one cannot compare the supervised individual’s rights in this posture with rights before conviction); United States v. Warren, 186 F.3d 358, 366 (3d Cir. 1999) (“Standard conditions of probation include restrictions on a defendant’s right to travel” (citing 18 U.S.C. § 3563(b)(13) & (14)); Alonzo v. Rozanski, 808 F.2d 637, 638 (7th Cir. 1986) (no liberty or property interest to live in another state); Williams v. Wisconsin, 336 F.3d 576, 581 (7th Cir. 2003) (convicted persons have no right to control where they live in the United States; the right to travel is extinguished for the entire balance of their sentences); Bagley v. Harvey, 718 F.2d 921, 924 (9th Cir. 1983) (same).
Supervised individuals do not have a constitutional right to relocate. Sending states have no obligation to allow a supervised individual to travel to or relocate to another state. Except as outlined in the ICAOS and its rules, member states are not obligated to assume jurisdiction and supervision over individuals from other states. The process for relocating and the responsibilities of states to approve or accept such relocations are governed by federal law and interstate agreements like the ICAOS.