In 1934, Congress authorized the creation of interstate Compacts on crime control, which led to the 1937 Interstate Compact for the Supervision of Parolees and Probationers. Also referred to as the Interstate Compact for Probation and Parole or the Uniform Law on the Supervision of Probationers and Parolees (hereafter “ICPP”). Pursuant to 4 U.S.C. 112 (2004), Congress granted the following consent:
(a) The consent of Congress is hereby given to any two or more States to enter into agreements or Compacts for cooperative effort and mutual assistance in the prevention of crime and in the enforcement of their respective criminal laws and policies, and to establish such agencies, joint or otherwise, as they may deem desirable for making effective such agreements and Compacts.
(b) For the purpose of this section, the term “States” means the several States and Alaska, Hawaii, the Commonwealth of Puerto Rico, the Virgin Islands, Guam, and the District of Columbia.
This consent, given to the states in advance of any Compact actually being in place, was the basis of not only the ICPP, but also serves as consent to other agreements such as the Interstate Juvenile Compact and the Interstate Compact for Adult Offender Supervision. See Doe v. Pennsylvania Bd. of Prob. & Parole, 513 F.3d 95, 99 (fnl) (3d Cir. 2008). Prior to the adoption of the ICPP, there was no formal means for controlling the interstate movement of probationers and parolees. In many circumstances, courts and paroling authorities exercised discretion regarding an offender’s permission to engage in interstate travel or relocation. Often, a receiving state obtained little or no notice of an offender’s relocation. The ICPP served as the primary means for controlling the interstate movement of offenders until its replacement by the ICAOS.