Thursday, May 9, 2019

Milestones: In re Extradition of Strunk, 293 F.Supp.2d 1117 (E.D. Cal. Nov. 12, 2003)


Philippines sought a U.S. citizen's extradition from California, based on a charge that the defendant murdered his wife Nida Blanca, a popular actress in the Philippines. A third party confessed to the killing, and in the confession named the defendant as the one who masterminded the crime. In exchange for the confession, the Filipino government paid money to the third party's family. The third party later repudiated the confession in a public hearing.

The court denied extradition and released the defendant from custody immediately. The court found that evidence submitted by the Philippines, based on a recanted confession obtained by payment of money, did not constitute probable cause for extradition.


Nida Blanca's Wikipedia page is here: She had a 50-year career, and was considered one of the Philippines' greatest actresses. On the legal side, however, this case is notable for setting the floor for an extradition, which is not easy to beat.

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