Martinez Santoyo v. Boyden, 130 F.4th 784

Jose Trinidad Martinez Santoyo was sought for extradition to Mexico to face charges of intentional aggravated homicide, related to a 2013 shooting.
Mexico issued an arrest warrant in 2014, and formally requested his extradition in July 2022.
The United States arrested Santoyo in May 2022, after a provisional arrest warrant, and released him on bail pending extradition proceedings.
A magistrate judge certified his extradition in February 2023, and Santoyo petitioned for habeas corpus, challenging this certification.
The key claim was that the extradition should be barred due to the "lapse of time" provision in the U.S.-Mexico Extradition Treaty, which Santoyo argued incorporated the U.S. Constitution’s Sixth Amendment Speedy Trial right.
The district court rejected this argument, concluding the "lapse of time" language refers only to statute of limitations, not the Sixth Amendment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does the US-Mexico Extradition Treaty’s "lapse of time" provision incorporate the Sixth Amendment Speedy Trial right?	"Lapse of time" incorporates the Sixth Amendment; extradition should be barred due to delay.	Provision only refers to statutes of limitations, not speedy trial rights.	The "lapse of time" provision does not incorporate the Sixth Amendment; only statutes of limitations are relevant.

Kamrin v. United States, 725 F.2d 1225 (9th Cir. 1984) (delay in seeking extradition may be considered by Secretary of State but not as a judicial defense)
Medellín v. Texas, 552 U.S. 491 (2008) (treaty interpretation starts with text, with reference to history and practice)
Prasoprat v. Benov, 421 F.3d 1009 (9th Cir. 2005) (extradition hearings are not criminal trials)
United States v. Knotek, 925 F.3d 1118 (9th Cir. 2019) (judiciary’s role in extradition proceedings is narrow)
Sainez v. Venables, 588 F.3d 713 (9th Cir. 2009) (extradition proceedings only to certify probable cause, not determine guilt)