United States Extradition Law — Case Law, Legal Framework and Procedure
Extradition cases involving United States — Requested and Requesting State
Connected jurisdictions
🇮🇹Italy32 cases🇬🇧United Kingdom4 cases🇩🇪Germany4 cases🇸🇬Singapore3 cases🇹🇷Turkey3 cases🇳🇿New Zealand3 cases🇯🇲Jamaica2 cases🇧🇿Belize2 cases🇨🇷Costa Rica2 cases🇦🇺Australia2 cases🇨🇾Cyprus1 case🇮🇶Iraq1 case🇨🇴Colombia1 case🇨🇱Chile1 case🇷🇸Serbia1 case🇹🇭Thailand1 case🇵🇪Peru1 case🇮🇱Israel1 case🇦🇷Argentina1 case🇿🇦South Africa1 case🇬🇭Ghana1 case🇲🇽Mexico1 case🇵🇱Poland1 case
Key Resources
Case Law
Extradition habeas review is limited to jurisdiction, treaty coverage and probable cause
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Summary
The petitioner challenged the certification of his extraditability to Israel, where he was sought for prosecution for attempted murder and related offences arising from an alleged organized-crime plot. He argued that the extradition court lacked jurisdiction because United States authorities had secured his transfer from Malaysia through deception and unlawful conduct, and further claimed that the evidence submitted by Israel did not establish probable cause. The District Court held that, under the Ker–Frisbie doctrine, even an irregular or unlawful rendition does not ordinarily deprive a court of jurisdiction, absent conduct comparable to the extreme torture or brutality contemplated by the narrow Toscanino exception. It also found that the United States–Malaysia extradition treaty did not apply because the petitioner had not been transferred pursuant to that treaty and concluded that the evidentiary record was sufficient to support probable cause. The habeas petition and the request for a stay pending appeal were therefore denied, subject to a one-week administrative stay allowing an application to the Court of Appeals.
29/06/2026 · United States District Court for the Southern District of New York · 25-CV-05712 (JAV), 2026 WL 1864974
🇺🇸United States → 🇮🇱Israel
GrantedExtraditionForeign conviction and detailed judicial findings are sufficient to establish probable cause for extradition
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Summary
The court certified extradition to Peru, emphasizing the limited role of the extradition court under 18 U.S.C. § 3184. The court held that a foreign conviction—particularly one obtained after the defendant participated in trial proceedings—is ordinarily sufficient to establish probable cause. Even assuming the conviction was treated like an in absentia conviction, the detailed findings of the Peruvian courts independently established probable cause. The decision also reaffirmed that U.S. courts do not second-guess foreign criminal proceedings or procedural rulings so long as treaty requirements are satisfied.
23/06/2026 · United States District Court for the Central District of California · 2:26-cv-00400-MEMF-MBK, 2026 WL 1811832
🇺🇸United States → 🇵🇪Peru
GrantedExtraditionAuthenticated foreign investigative materials and hearsay may establish probable cause for extradition
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Summary
The court certified extradition to Thailand after finding that a detailed affidavit from a Thai prosecutor, supported by hearsay summaries of witness statements and financial evidence, was sufficient to establish probable cause. The court emphasized that extradition proceedings are not trials, that hearsay is admissible, and that probable cause may rest on authenticated foreign investigative materials. The opinion also held that, once a court certifies extraditability, 18 U.S.C. § 3184 requires detention pending surrender, rejecting the view that courts retain discretion to continue bail after certification
22/06/2026 · United States District Court for the Northern District of Texas, Dallas Division · 3:26-MJ-215-BW, 2026 WL 1786771
🇺🇸United States → 🇹🇭Thailand
GrantedExtraditionExtradition may be certified where treaty requirements, dual criminality and probable cause are established for concealing evidence and protecting an offender
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Summary
The United States, acting on behalf of the Republic of Türkiye, sought the extradition of Eylem Tok, a Turkish national, on charges of destroying, concealing or altering evidence under Article 281 of the Turkish Criminal Code and protecting an offender under Article 283 of the same code. The charges arose not from the underlying fatal traffic accident — which the record attributes entirely to her minor son, T.C. — but from her conduct in the hours immediately following it: taking a victim’s cell phone from security officers under a false pretext and concealing it, removing her son and two other minors from the accident scene before police could observe or question them, and flying with her son out of Türkiye on one-way tickets within three hours of the collision.Following an extradition hearing under 18 U.S.C. § 3184, Chief Magistrate Judge Cabell denied the relator’s motion to dismiss, denied her motion for release from custody, and certified her extraditability to the Secretary of State on both offences. The decision is a companion to In re Extradition of T.C., 740 F. Supp. 3d 10 (D. Mass. 2024), concerning the relator’s son, and it addresses in detail several recurring questions of U.S. extradition law: the minimum-gravity (one-year punishability) requirement and its interaction with treaty accessory clauses, the treatment of foreign-law expert evidence that contradicts the requesting State’s position, the dual criminality doctrine, the meaning of “charged with an offense” in a treaty that does not require a charging document, the probable cause standard, and the “special circumstances” test for bail pending extradition.
11/02/2025 · United States District Court for the District of Massachusetts · No. 24-MJ-01365-DLC; 765 F. Supp. 3d 46
🇺🇸United States → 🇹🇷Turkey
GrantedExtraditionCountry 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
Jeffrey Lehtman
Barnes & Thornburg LLP
Jeffrey Lehtman's practice focuses on assisting clients with internal and government investigations, global regulatory compliance, and complex cross-border litigation. Client feedback in Chambers Global describes Jeff as "extremely available no matter the issue at hand" and notes he is "business-minded and addresses what needs immediate action first." Clients say "…his advice is outstanding."
Jeff has particular experience counseling clients with regard to civil, criminal, and regulatory issues arising in their international operations, ranging from compliance strategies to mitigate potential risk to internal and government investigations. In addition to counseling clients on issues arising from day-to-day operations, he has represented multinational companies, financial institutions, fintech companies, professional sports teams, international development banks, and their officers and directors in connection with investigations before the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), the Financial Industry Regulatory Authority (FINRA), and numerous other domestic and foreign regulatory and government bodies.
Jeff’s substantive experience includes the Foreign Corrupt Practices Act (FCPA), the Anti-Terrorism Act (ATA), anti-money laundering (AML) regulations, and economic sanctions laws, as well as allegations relating to accounting and disclosure irregularities, insider trading and workplace misconduct. In addition, Jeff has experience advising clients in connection with international extradition matters and international assistance among regulatory authorities (MLATs).
Prior to joining Barnes & Thornburg, Jeff was a partner at boutique firms in Washington D.C. and an AmLaw 200 firm. In addition, Jeff was previously Senior Regional Counsel at Citibank, overseeing regulatory, litigation and corporate matters involving Latin America. He also served as a Trial Attorney in the Office of International Affairs within the DOJ's Criminal Division.
Jeff has particular experience counseling clients with regard to civil, criminal, and regulatory issues arising in their international operations, ranging from compliance strategies to mitigate potential risk to internal and government investigations. In addition to counseling clients on issues arising from day-to-day operations, he has represented multinational companies, financial institutions, fintech companies, professional sports teams, international development banks, and their officers and directors in connection with investigations before the U.S. Securities and Exchange Commission (SEC), the U.S. Department of Justice (DOJ), the Financial Industry Regulatory Authority (FINRA), and numerous other domestic and foreign regulatory and government bodies.
Jeff’s substantive experience includes the Foreign Corrupt Practices Act (FCPA), the Anti-Terrorism Act (ATA), anti-money laundering (AML) regulations, and economic sanctions laws, as well as allegations relating to accounting and disclosure irregularities, insider trading and workplace misconduct. In addition, Jeff has experience advising clients in connection with international extradition matters and international assistance among regulatory authorities (MLATs).
Prior to joining Barnes & Thornburg, Jeff was a partner at boutique firms in Washington D.C. and an AmLaw 200 firm. In addition, Jeff was previously Senior Regional Counsel at Citibank, overseeing regulatory, litigation and corporate matters involving Latin America. He also served as a Trial Attorney in the Office of International Affairs within the DOJ's Criminal Division.
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.
Attorney Bıçak graduated from Bilkent University Faculty of Law in 2018 with advanced English legal training. He also pursued postgraduate studies in international trade and corporate law. During his legal education, he served as President of ELSA (European Law Students’ Association), one of Europe’s largest law student organizations, where he organized and coordinated numerous international legal projects and conferences.
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.
His practice areas include extradition and international judicial cooperation, cross-border litigation and dispute resolution, international commercial law, maritime and transportation law, international investment law, arbitration and mediation, corporate and regulatory compliance, white-collar and financial crime-related matters, and INTERPOL-related international criminal cooperation matters.
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.
Attorney Bıçak graduated from Bilkent University Faculty of Law in 2018 with advanced English legal training. He also pursued postgraduate studies in international trade and corporate law. During his legal education, he served as President of ELSA (European Law Students’ Association), one of Europe’s largest law student organizations, where he organized and coordinated numerous international legal projects and conferences.
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.
His practice areas include extradition and international judicial cooperation, cross-border litigation and dispute resolution, international commercial law, maritime and transportation law, international investment law, arbitration and mediation, corporate and regulatory compliance, white-collar and financial crime-related matters, and INTERPOL-related international criminal cooperation matters.
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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