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Case Law
Extradition to the United States granted: constitutional reform allowing extradition of Costa Rican nationals applied to pending requests
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Summary
The case concerned appeals by the Public Prosecutor and the Attorney General’s Office against a first-instance decision refusing the extradition of a Costa Rican national requested by the United States for prosecution for cocaine trafficking and conspiracy offences. The first-instance court had held that the 2025 reform of Article 32 of the Costa Rican Constitution, which permits the extradition of nationals in cases of international drug trafficking and terrorism, could not apply to facts occurring before the reform entered into force. The Court of Appeal reversed that conclusion. Relying on binding Constitutional Chamber case law, it held that extradition is a procedural mechanism of international cooperation and that the constitutional reform was immediately applicable to pending extradition proceedings. The Court further reasoned that the Costa Rica–United States extradition treaty had already allowed, since 1991, the extradition of nationals where domestic constitutional law did not prohibit it; the 2025 reform therefore removed the internal constitutional obstacle rather than creating a new substantive offence or punishment. Since the first-instance court had already found that the treaty requirements were met, including double criminality, legality and non-prescription, the Court of Appeal granted extradition in deferred form, subject to the prior resolution of pending Costa Rican criminal proceedings and to formal assurances from the United States on speciality, non-imposition of death penalty or life imprisonment, and a maximum prison term not exceeding fifty years.
02/06/2026 · Tribunal de Apelación de Sentencia Penal, Segundo Circuito Judicial de San José · 2026-0960
🇨🇷Costa Rica → 🇺🇸United States
Granted with conditionsExtraditionBail pending extradition refused: medical conditions manageable in custody and flight risk in US Extradition proceedings
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Summary
The case concerned a Singaporean requested person arrested in Singapore pursuant to a request by the United States in relation to alleged securities fraud and money laundering offences. Pending the extradition proceedings, the requested person sought release on bail on the ground that he was “sick or infirm”, relying on a serious eye condition and a history of bipolar disorder, and arguing that prison medical facilities were inadequate. The High Court held that the relevant threshold was not satisfied, as the medical evidence showed that the conditions either required no ongoing specialist management or could reasonably be managed by the Singapore Prison Service. The Court also considered, for completeness, that there was a real risk of flight given the seriousness of the charges and the prospect of extradition, and therefore dismissed the application for bail
26/05/2026 · General Division of the High Court of the Republic of Singapore · [2026] SGHC 114 / Criminal Motion No 46 of 2025
🇸🇬Singapore → 🇺🇸United States
Decision on precautionary measureExtraditionDigital evidence (WhatsApp messages) in extradition proceedings: interception law not in force and remittal ordered (Andrew Bennett extradition case)
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Summary
The case concerned extradition proceedings initiated by the United States against a Belizean attorney accused of participating in money laundering activities connected to drug trafficking. The extradition request relied in part on WhatsApp communications exchanged with an undercover DEA agent, which the lower courts had previously considered unlawfully obtained under Belize’s Interception of Communications Act and therefore unconstitutional. Before the Caribbean Court of Justice, it emerged that the statute relied upon by the lower courts had not yet entered into force at the relevant time, rendering the prior findings per incuriam. The Court held that the constitutional issues concerning the use of WhatsApp communications without judicial authorisation had not been properly argued and should not be resolved hypothetically on appeal. The decisions of the lower courts were therefore set aside and the matter remitted to the High Court for reconsideration of the constitutional questions.
15/05/2026 · Caribbean Court of Justice · [2026] CCJ 7 (AJ) BZ
🇧🇿Belize → 🇺🇸United States
Reversal and remandExtraditionExtradition and double criminality: transit of drugs through the requesting State may satisfy importation offences
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Summary
For the purposes of extradition and the assessment of double criminality, drug trafficking offences may be considered “importation offences” even where the narcotics merely transit through the requesting State, provided that the Record of the Case supports a reasonable inference that the drugs entered, or were intended to enter, that jurisdiction in the context of the alleged conspiracy. Leave to appeal was further denied on the ground that the Record supported an inference that the requested person, as a member of the smuggling operation responsible for customs paperwork in the requested State, knew both the method and the route through the requesting State that the drugs would take.
05/05/2026 · Supreme Court of New Zealand · NZSC 46/2026
🇳🇿New Zealand → 🇺🇸United States
Procedural orderExtraditionExtradition and sought person’s right to family contacts (telephone conversations and video calls)
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Summary
In extradition matters, decisions concerning family contacts issued by the Court of Appeal are subject to appeal pursuant to Article 111(7) of the Italian Constitution, both when the Court acts as the judicial authority conducting the proceedings and, after the extradition judgment has become final, as the execution judge. The Court of Appeal may not reject a request for telephone conversations (including video calls) with the wife and minor child of the requested person merely by referring to obstructive reasons “for security purposes” or to communications received from the U.S. authorities. In the present case, there was no independent assessment showing that, having regard to the specific arrangements for the telephone communications and to the special protection afforded to contacts with minor children, there actually existed security concerns or a risk of interference with evidence.
05/05/2026 · Italian Supreme Court · 16620/2026
🇮🇹Italy → 🇺🇸United States
Decision on precautionary measureExtraditionExtradition detention maintained: no special circumstances justifying bail pending surrender
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Summary
The case concerned extradition proceedings under the U.S.–Germany extradition treaty, in which the defendant sought revocation of a detention order entered pending extradition. He argued that special circumstances justified release, relying on his medical condition, alleged delays in the extradition proceedings, and family responsibilities, and further maintained that he was not a flight risk. On de novo review, the District Court held that none of those factors amounted to special circumstances capable of overcoming the presumption against bail in extradition cases. Because no special circumstances were established, the Court denied the motion to revoke the detention order without reaching a final determination on flight risk or danger to the community.
29/04/2026 · United States District Court for the Central District of California · 2:26-cv-02074-SB-MAA; 2026 WL 1455318
🇺🇸United States → 🇩🇪Germany
Decision on precautionary measureExtraditionDouble criminality assessed at the time of the extradition request, not at the time of the alleged conduct
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Summary
The case concerned an application for judicial review challenging the surrender of the requested person from Australia to the United States in relation to offences connected with the alleged training of Chinese military pilots in South Africa between 2009 and 2012. The requested person argued that extradition was unlawful because the conduct relied upon by the United States did not constitute offences under Australian law at the time the alleged conduct occurred, the relevant Australian national security offences having entered into force only in 2018. The Federal Court of Australia rejected the application, holding that the U.S.–Australia Extradition Treaty does not impose a requirement of contemporaneous dual criminality. The Court found that the applicable dual criminality test is the one established by section 19(2)(c) of the Australian Extradition Act, which requires assessment by reference to the law in force at the time the extradition request was received rather than at the time of the alleged conduct. The judgment also contains a detailed analysis of the interaction between extradition treaties and domestic legislation, the incorporation of treaty provisions into Australian law through section 11 of the Extradition Act, and the limits of judicial review in extradition proceedings. The application was dismissed and the surrender decision upheld.
16/04/2026 · Federal Court of Australia · [2026] FCA 445
🇦🇺Australia → 🇺🇸United States
GrantedExtraditionExtradition: translation of General Prosecutor’s speech is not required (especially if the sought person is already aware of the charges)
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Summary
General Prosecutor's speech - by which the Office starts the extradition proceedings - does not fall either among the acts for which a written translation is mandatorily required, nor among those — to be considered essential for the accused to understand the charges against him — for which the judge may order a translation ex officio or upon request of a party. The case concerns a sought person who, at the time the application was filed, was fully aware of the allegations against him, having already been served with a pre-trial detention order, duly translated for him.
15/04/2026 · Italian Supreme Court · 14575/2026
🇮🇹Italy → 🇺🇸United States
GrantedExtraditionExtradition to Ghana certified: foreign conviction established probable cause for public funds and money laundering offences
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Summary
The case concerned Ghana’s request for the extradition of a former Chief Executive Officer of the Microfinance and Small Loans Centre, who had been convicted in Ghana and sentenced to ten years’ imprisonment for multiple offences involving stealing, conspiracy, willfully causing financial loss to the State, causing loss to public property and money laundering. The United States District Court for the District of Nevada certified extradition, holding that the extradition treaty between the United States and Ghana, together with the United Nations Convention against Corruption, was valid and in force and covered the relevant offences. The Court rejected the argument that dual criminality was lacking because the Ghanaian offences had a lower mens rea threshold than their United States analogues, emphasizing that dual criminality does not require identity of statutory elements, but only that the underlying conduct be criminal in both countries. On the facts alleged, the conduct would be prosecutable in the United States as theft or receipt of stolen government property and money laundering. The Court also held that Ghana’s judgment of conviction, together with the authenticated affidavits, was sufficient to establish probable cause, even though the conviction had been entered after the requested person failed to return to Ghana during trial. The Court therefore certified extradition and committed the requested person to the custody of the United States Marshal pending the Secretary of State’s final surrender decision. According to the subsequent Department of Justice press release, the Secretary of State authorized surrender and the requested person was extradited to Ghana on 8 June 2026.
09/04/2026 · United States District Court, District of Nevada · 2:25-mj-00861-DJA-1
🇺🇸United States → 🇬🇭Ghana
GrantedExtraditionThe Minister’s request for revocation of the measure leaves the Court with no discretion
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Summary
The request by the Minister of Justice for the revocation of the custodial measure leaves no room for discretion, as the law provides that “revocation shall always be ordered if the Minister of Justice so requests.” In such cases, where the proceedings are pending before the Court of Cassation, that Court has jurisdiction to decide on the revocation of the measure, and the immediate release of the person sought for extradition must be ordered.
27/03/2026 · Italian Supreme Court · 12897/2026
🇮🇹Italy → 🇺🇸United States
DeniedExtraditionRevocation of precautionary measure for failure to transmit the documents within 45 days from the arrest
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Summary
The failure or delay in transmitting the documents, expressly required by the Treaty, to the Ministry of Justice and/or the Ministry of Foreign Affairs entails the immediate loss of effectiveness of the precautionary measure. Indeed, since the matter concerns restrictions on personal liberty, the mandatory time limits laid down by the treaty provisions and by the corresponding rules of the Code of Criminal Procedure must be regarded as essential and applied with the utmost strictness (as affirmed by the Constitutional Court).
20/03/2026 · Italian Supreme Court · 10777/2026
🇮🇹Italy → 🇺🇸United States
Decision on precautionary measureExtraditionExtradition to the United States refused: Costa Rican constitutional reform allowing nationals’ extradition not applied retroactively
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Summary
The case concerned a United States request for the extradition of a Costa Rican national wanted for prosecution in the Southern District of New York for cocaine trafficking and conspiracy offences. The Tribunal Penal found that the formal requirements of the Costa Rica–United States extradition treaty were satisfied, including double criminality, legal basis, validity of the prosecution, and the absence of political or military offences. It also noted that any surrender would require formal assurances on speciality and on the non-imposition of prohibited penalties, including death penalty, life imprisonment or a prison sentence exceeding fifty years. However, the Court refused extradition on the ground that the alleged conduct pre-dated the 2025 constitutional reform of Article 32 of the Costa Rican Constitution, which allowed the extradition of nationals in cases of international drug trafficking and terrorism. Relying on the principle of non-retroactivity and on a previous appellate decision, the Court held that the reform could not apply to facts occurring before its entry into force. Since the requested person was a Costa Rican national and the alleged conduct occurred before the reform, extradition was denied, although the Court held that Costa Rica should prosecute the facts domestically under Costa Rican law.
09/03/2026 · Tribunal Penal, First Judicial Circuit of the Atlantic Zone, Limón · 2026-000195
🇨🇷Costa Rica → 🇺🇸United States
DeniedExtraditionExtradition decision (including procedural rulings) must be rendered by the Court of Appeal and not by a single delegated judge
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Summary
The decision on an extradition request—even where it takes the form of a ruling of no need to proceed due to the person’s absence from the national territory—falls within the jurisdiction of the Court of Appeal sitting in its collegiate composition, and not of a delegated judge. Accordingly, where, as in the present case, the delegated judge has exercised a power that the legal system reserves to the Court of Appeal, the impugned decision must be deemed affected by absolute nullity for lack of judicial capacity, as it entails a violation of the constitutional principle of the natural judge pre-established by law.
12/02/2026 · Italian Supreme Court · 12518/2026
🇮🇹Italy → 🇺🇸United States
Rejected (procedural grounds)ExtraditionExtradition to USA for bomb attacks linked to animal testing: articles 3 and 6 ECHR challenges rejected
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Summary
The case concerned a request by the United States for the extradition of the requested person to stand trial for several bombing offences allegedly committed in California in 2003 against companies linked to animal testing activities. The defence argued that extradition should be barred because of the risk of prejudice connected to the requested person’s political beliefs, alleged defects in the superseding indictment, and potential violations of Articles 3 and 6 ECHR arising from detention conditions and possible political interference by the current U.S. administration. The Westminster Magistrates’ Court rejected those arguments, holding that the proceedings concerned ordinary violent criminal offences and that there was no concrete evidence of political motivation or improper executive interference. The Court further held that the requested person would benefit from the procedural guarantees of the U.S. federal justice system, including legal representation, independent judicial oversight, and appellate remedies. Extradition was therefore ordered, the Court finding no violation of Articles 3 or 6 ECHR.
06/02/2026 · Westminster Magistrates’ Court · The Government of the United States of America -v- Daniel Andreas San Diego
🇬🇧United Kingdom → 🇺🇸United States
GrantedExtraditionExtension of pre-trial detention due to the “particular complexity” of the case
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Summary
The particular complexity of the case, including procedural and substantive issues raised by the Defence, may justify—where analyses and further inquiries are required—the extension of the custodial measure. Such activities also include engaging in communications with foreign authorities within the framework of the so-called Petruhhin mechanism.
04/02/2026 · Italian Supreme Court · 8409/2026
🇮🇹Italy → 🇺🇸United States
Decision on precautionary measureExtraditionExtradition to USA and loss of effectiveness of precautionary measure in case of failure to deliver extradition request (and supporting documents) within 45 days
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Summary
Extradition to the United States and loss of effectiveness of pre-trial detention in the absence of a timely extradition request (and supporting documents) within 45 days The extradition treaty between Italy and the United States provides that, within 45 days of the arrest, the United States must transmit to Italy the formal extradition request together with the documentation required under Article X. The purpose is to prevent provisional arrest from turning into prolonged detention without the formal legal basis constituted by a proper extradition request. In the present case, the arrest was carried out on 10/10/2025, from which date the above-mentioned peremptory time limit began to run. Since the Court of Appeal rendered its decision at a time when, within the mandatory time limits set by the Treaty, neither the extradition request nor the required documentation had yet been received — as was instead necessary — the challenged order must be quashed without remand and the custodial measure currently in force must be revoked.
19/01/2026 · Italian Supreme Court · 14484/2026
🇮🇹Italy → 🇺🇸United States
Decision on precautionary measureExtraditionExtradition and replacement of the extradition title for the same facts
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Summary
The replacement by the requesting State of the extradition title for the same facts, prior to the decision of the Court of Appeal, does not constitute a ground precluding a finding of extraditability. It has been held that “there is nothing to prevent, provided that the cause of action remains unchanged, the legal basis of the extradition request from being subsequently and formally replaced by the requesting State before the Court of Appeal renders its decision. Such a novatio integrates the extradition request, thereby becoming part of it, and does not infringe any defence rights, since the person concerned is made aware of it prior to the decision.”
20/11/2025 · Italian Supreme Court · 41697/2025
🇮🇹Italy → 🇺🇸United States
Decision on precautionary measureExtraditionExtradition Mexico–United States: amparo dismissed due to withdrawal of the extradition request and cessation of effects
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Summary
Where the requesting State withdraws the extradition request and the competent authority declares the extradition procedure moot, setting aside the extradition decision, the effects of the challenged act cease. As a result, the amparo proceedings must be dismissed, including any constitutional challenge to the treaty provision whose application depended on that extradition decision.
05/11/2025 · Suprema Corte de Justicia de la Nación · 223/2024
🇲🇽Mexico → 🇺🇸United States
Procedural orderExtraditionThe seizure (urgently executed by the police) must be validated by the Court of Appeal
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Summary
In extradition matters, the seizure of the corpus delicti and of items pertaining thereto, ordered on an urgent basis by the judicial police within the framework of an extradition procedure, must be validated by the Court of Appeal. The latter is required to provide reasons—on the basis of the applicable conventional framework, as well as Article 714(1) of the Italian Code of Criminal Procedure, insofar as not derogated—regarding the existence of a nexus of pertinence between the seized assets and the offence underlying the extradition request, through an assessment of the evidentiary needs put forward by the requesting foreign authority (in the present case, a seizure carried out by the judicial police in the context of an extradition procedure initiated by the United States of America).
25/09/2025 · Italian Supreme Court · 35238/2025
🇮🇹Italy → 🇺🇸United States
Procedural orderExtraditionCompeting extradition requests: decision to prioritise the United States quashed for unfairness and factual errors
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Summary
The case concerned a Portuguese national facing two competing extradition claims for substantially overlapping cybercrime-related conduct: a United States extradition request under Part 2 of the Extradition Act 2003 and a Portuguese arrest warrant under Part 1. The requested person preferred extradition to Portugal and challenged the Home Secretary’s decision under section 179 of the 2003 Act to defer the Portuguese warrant until the United States request had been disposed of. The High Court held that the decision-making process was procedurally unfair because the Home Secretary had refused to receive representations from the requested person, the United States and Portugal, despite the significant consequences of choosing between competing extradition claims. Relying also on the CJEU judgment in OP v Procureur de la République, the Court interpreted section 179 consistently with the need to consider all the circumstances of the case, including the interests of the requested person. The Court further found that the decision was vitiated by material factual errors and by a failure to take relevant considerations into account, and therefore quashed the decision so that the matter could be reconsidered by the Home Secretary.
11/09/2025 · High Court of Justice, King’s Bench Division, Administrative Court · [2025] EWHC 2293
🇬🇧United Kingdom → 🇺🇸United States
Procedural orderExtraditionCountry Contributor
Bruce Zagaris
Berliner, Corcoran & Rowe LLP - Washington, DC
Bruce Zagaris is a partner in the Washington, D.C. firm of Berliner, Corcoran & Rowe LLP.
His practice focuses on international white collar crime, including tax controversy, money movement, international evidence gathering, extradition and INTERPOL, prisoner transfer matters, and the Foreign Agents Registration Act (FARA). Bruce has successfully challenged INTERPOL Red and Yellow notices. He has also authored a chapter about INTERPOL in his book International White Collar Crime (Cambridge University Press, 2015).
Since 1985, he has served as editor-in-chief of the International Enforcement Law Reporter, a weekly and monthly journal on international enforcement law.
Bruce has been teaching law throughout his entire career. He has served as an adjunct professor, and since 2016, he has been teaching at Texas A&M Masters Program, the school’s Wealth Management and Risk Management course.
Bruce regularly appears as an expert witness in extradition, evidence gathering, international tax, financial regulatory, and money laundering cases. He has authored and edited six books and many law review and other articles. He has worked as a consultant for international organizations on a variety of international enforcement matters.
His practice focuses on international white collar crime, including tax controversy, money movement, international evidence gathering, extradition and INTERPOL, prisoner transfer matters, and the Foreign Agents Registration Act (FARA). Bruce has successfully challenged INTERPOL Red and Yellow notices. He has also authored a chapter about INTERPOL in his book International White Collar Crime (Cambridge University Press, 2015).
Since 1985, he has served as editor-in-chief of the International Enforcement Law Reporter, a weekly and monthly journal on international enforcement law.
Bruce has been teaching law throughout his entire career. He has served as an adjunct professor, and since 2016, he has been teaching at Texas A&M Masters Program, the school’s Wealth Management and Risk Management course.
Bruce regularly appears as an expert witness in extradition, evidence gathering, international tax, financial regulatory, and money laundering cases. He has authored and edited six books and many law review and other articles. He has worked as a consultant for international organizations on a variety of international enforcement matters.
Country Contributor
Joshua Kolsrud
Kolsrud Law Offices - Phoenix
Josh Kolsrud is a former federal prosecutor turned aggressive criminal defense attorney with deep experience in complex international and federal criminal cases.
A native of Phoenix, Arizona, Josh graduated summa cum laude from Arizona State University’s Barrett Honors College in 2004 and received his Juris Doctor from the University of Miami School of Law in 2007.
He began his career at the Maricopa County Attorney’s Office and later served as Senior Trial Attorney for the Coconino County Attorney’s Office. Josh was then recruited to the United States Attorney’s Office, where he spent more than five and a half years as an Assistant U.S. Attorney prosecuting cases involving human trafficking, drug trafficking, illegal reentry, gun crimes, white-collar fraud, and other federal offenses with cross-border elements. He successfully authored and won two appeals before the Ninth Circuit Court of Appeals.
Josh was personally recruited by the Attorney General of the Republic of Palau to lead an anti-human sex trafficking operation in the South Pacific. His efforts helped rescue hundreds of victims from sexual slavery and included prosecuting one of the only jury trials in Palau’s history.
With extensive experience in transnational crime, international investigations, and federal appellate practice, Josh brings unique insight into extradition and cross-border criminal matters.
A native of Phoenix, Arizona, Josh graduated summa cum laude from Arizona State University’s Barrett Honors College in 2004 and received his Juris Doctor from the University of Miami School of Law in 2007.
He began his career at the Maricopa County Attorney’s Office and later served as Senior Trial Attorney for the Coconino County Attorney’s Office. Josh was then recruited to the United States Attorney’s Office, where he spent more than five and a half years as an Assistant U.S. Attorney prosecuting cases involving human trafficking, drug trafficking, illegal reentry, gun crimes, white-collar fraud, and other federal offenses with cross-border elements. He successfully authored and won two appeals before the Ninth Circuit Court of Appeals.
Josh was personally recruited by the Attorney General of the Republic of Palau to lead an anti-human sex trafficking operation in the South Pacific. His efforts helped rescue hundreds of victims from sexual slavery and included prosecuting one of the only jury trials in Palau’s history.
With extensive experience in transnational crime, international investigations, and federal appellate practice, Josh brings unique insight into extradition and cross-border criminal matters.
Country Contributor
Vahdet Talha Bıçak
Bıçak Law Firm - Chicago
Attorney Vahdet Talha Bıçak is a Turkish attorney focusing on international business law, cross-border disputes, international judicial cooperation, extradition-related matters, investment law, maritime law, and commercial litigation. He is part of the management team of Bıçak Law Firm, an Ankara-based full-service law firm representing domestic and international clients in complex cross-border legal matters.
He currently continues his academic and professional activities in Chicago, United States, where he has further expanded his comparative and international legal expertise. His international exposure and practical experience enable him to work effectively on matters involving multi-jurisdictional disputes, international cooperation mechanisms, and transnational legal risks.
His legal practice includes advising multinational corporations, foreign investors, embassies, and international commercial actors on Turkish and international legal matters. He has experience in international arbitration, cross-border investment disputes, international trade, maritime disputes, compliance, regulatory matters, and international commercial litigation.
Attorney Bıçak has also been involved in matters relating to international criminal cooperation, comparative law, and extradition-related legal issues. His growing interest in extradition law, European Arrest Warrant practice, INTERPOL-related matters, and international judicial cooperation has led him to contribute to comparative legal research and case-law analysis in this field.
He is fluent in Turkish and English.
Attorney Vahdet Talha Bıçak is a member of the Ankara Bar Association and previously served as President of ELSA Ankara. He currently continues his professional activities through Bıçak Law Firm while further developing his international legal practice in the United States.
He currently continues his academic and professional activities in Chicago, United States, where he has further expanded his comparative and international legal expertise. His international exposure and practical experience enable him to work effectively on matters involving multi-jurisdictional disputes, international cooperation mechanisms, and transnational legal risks.
His legal practice includes advising multinational corporations, foreign investors, embassies, and international commercial actors on Turkish and international legal matters. He has experience in international arbitration, cross-border investment disputes, international trade, maritime disputes, compliance, regulatory matters, and international commercial litigation.
Attorney Bıçak has also been involved in matters relating to international criminal cooperation, comparative law, and extradition-related legal issues. His growing interest in extradition law, European Arrest Warrant practice, INTERPOL-related matters, and international judicial cooperation has led him to contribute to comparative legal research and case-law analysis in this field.
He is fluent in Turkish and English.
Attorney Vahdet Talha Bıçak is a member of the Ankara Bar Association and previously served as President of ELSA Ankara. He currently continues his professional activities through Bıçak Law Firm while further developing his international legal practice in the United States.
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