United States v. Campbell
3:25-mj-00218
| N.D. Tex. | Jun 5, 2025Background
- The United States seeks to extradite Franklin Alexander Campbell to Ireland to face a money laundering charge linked to a 2017 fraudulent email scheme.
- Campbell, a Nigerian passport holder, had €23,625 transferred into his Irish bank account from a victim company, then quickly transferred and withdrew those funds.
- Irish authorities allege Campbell knew or was reckless as to the criminal origin of the funds; a bench warrant issued after his failure to appear in Ireland, and he left the country.
- Campbell was found in Texas, arrested on the US extradition complaint, and argued against extradition and for release on bail.
- At a May 15, 2025, hearing, both parties presented evidence and argument; the court ultimately certified Campbell as extraditable and denied bail.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Probable cause for money laundering | Sufficient evidence links Campbell’s account/funds | No direct evidence he knew money was criminal | Probable cause established |
| Discriminatory prosecution or treaty bar | No substantial evidence of discriminatory motive | Prosecution may be due to race/nationality | No substantial grounds; exception not triggered |
| Release on bail: risk of flight requirement | Campbell presents flight risk (left Ireland, etc.) | Family/community ties, US citizenship application | Not shown by clear and convincing evidence |
| Release on bail: special circumstances | No extraordinary or rare grounds for release | Medical/family needs, bail possible in Ireland | No special circumstances warranting bail |
Key Cases Cited
- Terlinden v. Ames, 184 U.S. 270 (1902) (providing foundational definition for extradition)
- Wright v. Henkel, 190 U.S. 40 (1903) (establishing presumption against bail in extradition)
- Collins v. Loisel, 259 U.S. 309 (1922) (guilt or innocence not decided by extradition court)
- United States v. Kin-Hong, 110 F.3d 103 (3d Cir. 1997) (courts do not review requesting country’s legal system in extradition proceedings)
- Russell v. United States, 805 F.2d 1215 (5th Cir. 1986) (no bail presumption in extradition; reverse is true)