In Re: In the Matter of the Extradition of Zhenly Ye Gon

CourtDistrict Court, District of Columbia
DecidedOctober 15, 2009
DocketMisc. No. 2008-0596
StatusPublished

This text of In Re: In the Matter of the Extradition of Zhenly Ye Gon (In Re: In the Matter of the Extradition of Zhenly Ye Gon) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re: In the Matter of the Extradition of Zhenly Ye Gon, (D.D.C. 2009).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

In the Matter of the Extradition of

Zhenly Ye Gon Misc. No. 08-596 (JMF)

MEMORANDUM OPINION

Currently pending and ready for resolution is the United States’ Motion and

Memorandum of Law in Support of Detention (“Mot.”) [#53]. For the reasons stated herein, the

government’s motion will be granted. BACKGROUND

Respondent Zhenly Ye Gon is a naturalized Mexican citizen who was born in China.

Complaint for Arrest with a View Towards Extradition (18 U.S.C. § 3184) (“Compl.”) at ¶ 23.

On July 23, 2007, he was arrested in Maryland on a federal drug complaint issued by this court.

Mot. at 1. The respondent was then indicted in the United States on the charge of conspiring to

aid and abet the manufacture of 500 grams or more of methamphetamine, with the knowledge

that it would be imported into the United States, in violation of 21 U.S.C. §§ 959 and 963, and

18 U.S.C. § 2. Id. Subsequently, the Mexican government formally requested the respondent’s

extradition pursuant to the treaty between the United States and Mexico, so that he could face numerous charges including violations of Mexican organized crime, drug, firearms and

explosives, and money laundering laws. Compl. ¶ 5. On August 28, 2009, the indictment against

the respondent was dismissed with prejudice. The government has now moved for the

respondent’s detention pending the resolution of the Mexican government’s request for

extradition. DISCUSSION

I. Legal Standard

Unlike the Bail Reform Act, 18 U.S.C. § 3141 et seq., which identifies various criteria for

the issuance of bail in criminal cases, the federal statute governing the extradition of foreign nationals from the United States to their home countries, 18 U.S.C. § 3184 et seq., makes no

mention of bail. See Beaulieu v. Hartigan, 554 F.2d 1, 2 (1st Cir. 1977) (“Unlike the situation

for domestic crimes, there is no presumption favoring bail [in extradition cases].”). Accord

United States v. Russell, 805 F.2d 1215, 1216 (5th Cir. 1986). Rather, there is a strong

presumption against the granting of bail in extradition cases.

In the 1903 seminal case of Wright v. Henkel, 190 U.S. 40 (1903), not only did the

Supreme Court state plainly that “bail should not ordinarily be granted in cases of foreign

extradition,” id. at 63, but it also discussed the incongruity between the granting of such relief in

the face of an extradition treaty to which the United States was a party:

The demanding government, which has done all that the treaty and the law require it to do, is entitled to the delivery of the accused on the issue of the proper warrant, and the other government is under obligation to make the surrender; an obligation which it might be impossible to fulfil[l] if release on bail were permitted. The enforcement of the bond, if forfeited, would hardly meet the international demand; and the regaining of the custody of the accused obviously would be surrounded with serious embarrassment. And the same reasons which induced the language used in the statute would seem generally applicable to release pending examination.

Id. at 62 (emphasis added). See also United States v. Leitner, 784 F.2d 159, 161 (2nd Cir. 1986)

(noting the added importance of detention where the individual whose extradition is sought was

charged with acts of terrorism). The Court did not, however, preclude the possibility that bail would ever be granted in an extradition case and indicated that circumstances might arise that

would warrant such relief: “We are unwilling to hold that the circuit courts possess no power in

respect of admitting to bail other than as specifically vested by statute, or that, while bail should

not ordinarily be granted in cases of foreign extradition, those courts may not in any case, and

whatever the special circumstances, extend that relief.” Id. at 63 (emphasis added).

Six years later, in the case of In re Mitchell, 171 F. 289 (S.D.N.Y. 1909), Judge Learned

Hand noted that bail in extradition cases was appropriate “only in the most pressing

circumstances, and when the requirements of justice are absolutely peremptory.” Id. at 289. In

2 that case, the court found the existence of special circumstance where the individual being held

was also party to a civil suit which implicated his entire fortune. Id. Judge Hand, however,

limited the period of release to the duration of the civil suit. Once the civil suit was concluded,

the respondent was to be remanded to jail. Id. at 290.

In United States v. Kin-Hong, 83 F.3d 523 (1st Cir. 1996), the district court concluded

that there were conditions of release that would adequately assure the appellee’s presence at

future proceedings. Id. The court of appeals reversed, however, and concluded that, while other

courts had granted bail where it appeared likely that the prisoners would be able to successfully

challenge their extraditions, there was no clear indication of the detainee’s ultimate success in

challenging the United Kingdom’s request to have him extradited to Hong Kong. Id. The

appellate court was similarly unpersuaded by the detainee’s argument that the attending

complexity in legal issues, namely the change in sovereignty over Hong Kong, would result in a

delay of the extradition proceedings. Id. at 525. The court therefore concluded that there were

no special circumstances which warranted the detainee’s release. Id.

Special circumstances were found one year later in United States v. Kirby, 106 F.3d 855

(9th Cir. 1997). In that case, the court of appeals upheld the district court’s finding of special

circumstances relating to three Irish citizens who had escaped from a Belfast jail. Id. at 857.

Affirming the lower court’s finding that the three individuals had experienced unusual delay in the appellate procedure and that another escapee had been granted bail were special

circumstances justifying bail, the court also noted the uniqueness of the case itself, one involving

the tensions between Protestants and Catholics in Northern Ireland, as support for its affirmation

of the lower court’s ruling. Id. at 863, 864-65.

Finally, in the recent decision of United States v. Ramnath, 533 F. Supp. 2d 662 (E.D.

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