Glucksman v. Henkel was a U.S Supreme Court case in 1910 that revolved around the extradition of an individual from one country to another for criminal prosecution. The petitioner, Glucksman, argued against his extradition from the United States to Russia on charges of forgery and embezzlement. He claimed that he could not be extradited because these crimes were not included in the treaty between the two countries at that time. However, after examining both Russian and American laws regarding forgery and embezzlement, as well as their interpretation within each legal system's context, it was determined by Justice Day delivering the opinion of court that these offenses fell under "fraud" which is indeed covered by said treaty. Therefore, Glucksman's argument was rejected and his extradition upheld.

In the dissenting opinion for Glucksman v. Henkel, Justice Harlan disagreed with the majority's decision to extradite Glucksman back to Russia without a proper examination of whether he would be tried and punished there solely based on his political beliefs. He argued that this violated both U.S.-Russia extradition treaty and fundamental principles of justice. The treaty stipulated that no person should be surrendered if their offense was political in nature, yet it seemed clear from evidence presented that Glucksman was being pursued due to his involvement in revolutionary activities against Russian government rather than any criminal act as claimed by Russia. Harlan also expressed concern over potential abuse of extradition process by foreign governments who could use false accusations of non-political crimes as pretext for persecuting their political enemies abroad.