In the 1925 case of Donegan v. Dyson, U.S. Marshal, the United States Supreme Court ruled on a dispute involving extradition procedures and due process rights under federal law. The petitioner, Donegan, was arrested in New York by U.S. Marshals at the request of British authorities who sought his return to England for trial on charges of embezzlement committed while he was serving as an officer in a British corporation operating in China. He challenged his arrest and detention arguing that they violated his constitutional rights because there were no existing treaties between Britain and China regarding extradition from America. The Supreme Court disagreed with Donegan's argument stating that it is within Congress’s power to enact laws providing for such extraditions even without specific treaty provisions covering them directly or indirectly; thus upholding Congressional authority over international legal matters related to American citizens' actions abroad.

In the dissenting opinion for Donegan v. Dyson, it was argued that the majority's decision to deny habeas corpus relief to a British subject who had been extradited from Canada on charges of fraud and conspiracy in violation of U.S. law was incorrect. The dissent contended that the extradition treaty between Great Britain and the United States did not cover such offenses as those charged against Donegan, thus making his arrest and detention illegal under international law. Furthermore, they believed that even if these crimes were covered by the treaty, there still existed insufficient evidence to justify Donegan's extradition according to its terms which required "such evidence of criminality as would justify his apprehension and commitment for trial" within both countries involved in an extradition agreement.