SANTOYO V. BOYDEN, No. 24-1967 (9th Cir. 2025)
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Jose Trinidad Martinez Santoyo was sought for extradition to Mexico to face charges of intentional aggravated homicide. In January 2014, a Mexican judge issued an arrest warrant for Santoyo, alleging he shot a man twice in the head after an argument. Mexico requested his provisional arrest in November 2018, and the United States filed a complaint in August 2021. Santoyo was arrested in May 2022 and released on bail in November 2022. Mexico formally requested his extradition in July 2022, providing various supporting documents. A magistrate judge certified the extradition in February 2023, and Santoyo challenged this certification via a habeas corpus petition.
The United States District Court for the Eastern District of California denied Santoyo's habeas corpus petition. Santoyo argued that the extradition treaty between the United States and Mexico incorporated the Sixth Amendment's Speedy Trial Clause, contending that the delay between the 2014 arrest warrant and the 2022 extradition request violated his speedy trial rights. The district court rejected this argument, holding that the treaty's "lapse of time" provision referred only to statutes of limitations, not to the Sixth Amendment's speedy trial protections.
The United States Court of Appeals for the Ninth Circuit reviewed the case and affirmed the district court's decision. The Ninth Circuit held that the "lapse of time" language in the extradition treaty does not incorporate the Sixth Amendment Speedy Trial Clause. The court emphasized that extradition proceedings are not criminal prosecutions and that the treaty's language refers to statutes of limitations rather than the constitutional right to a speedy trial. The court also noted that the judiciary's role in extradition is limited and that issues of delay are more appropriately addressed by the Secretary of State.
Court Description: Extradition. Affirming the district court’s denial of a habeas corpus petition challenging an order certifying the petitioner’s extradition to face charges in Mexico, the panel held that the “lapse of time” language in the extradition treaty between the United States and Mexico does not incorporate the Sixth Amendment Speedy Trial Clause.
The panel addressed other arguments in a concurrently filed memorandum disposition.
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