In the case of Valentine, Police Commissioner of New York City, et al. v. United States ex rel. B. Coles Neidecker in 1936, the U.S Supreme Court ruled that extradition treaties do not apply to fugitives who flee to a foreign country unless explicitly stated in the treaty itself. The case involved B.Coles Neidecker who was charged with embezzlement and fled from France to New York City before he could be tried by French authorities for his crimes committed while working at an American bank branch located in Paris, France. He was arrested upon arrival but sought habeas corpus relief on grounds that there were no provisions for his extradition under existing Franco-American treaties since they did not specifically mention embezzlement as an extraditable offense nor did they provide for reciprocal obligations between countries regarding such offenses.

In the dissenting opinion for Valentine v. United States ex rel. Neidecker, Justice Cardozo argued that extradition treaties should be interpreted in a way that respects the sovereignty of foreign nations and their ability to decide who they will extradite. He believed that it was not within the purview of U.S courts to interpret these agreements or make decisions about whether an individual could be extradited based on political offenses; rather, this decision should rest with executive branch officials who have expertise in international relations and diplomacy. Furthermore, he contended that if there were any ambiguity in treaty language regarding exceptions for political crimes, it would be more appropriate to defer to diplomatic negotiations than judicial interpretation.