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However, there is a “longstanding principle of American law that legislation of Congress, unless a contrary intent appears, is meant to apply only within the territorial jurisdiction of the United States.” Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247, 255, (2010)   “The presumption against extraterritoriality is only a presumption;…

I was having a few flashbacks to civil procedure class in a recent Federal extradition case recently.  In law school, we had to learn the International Shoe standard of “minimum contacts which do not disturb traditional notions of fair play and substantial justice” according to International Shoe, whereby a state…