## Facts

- The United Kingdom requested the extradition of William Joseph Quinn under 18 U.S.C. § 3184 and the 1972 U.S.–U.K. Extradition Treaty.
- Quinn was sought to stand trial for a 1975 murder of Police Constable Tibble and conspiracies to cause explosions in London in 1974 and 1975, allegedly connected to IRA activity.
- A U.S. magistrate conducted an extradition hearing and certified Quinn as extraditable under the treaty and statute.
- Quinn petitioned for habeas corpus in federal district court, asserting the treaty’s political offense exception barred extradition because the alleged crimes were political acts arising from the Northern Ireland conflict.
- The district court granted habeas relief and set aside the extradition certification on political-offense grounds.
- The United States, acting on behalf of the United Kingdom, appealed.

## Issues

1. Whether murder of a police constable and conspiracies to bomb targets in London qualified as “political offenses” under the treaty’s political offense exception, barring extradition.
2. What limits apply to federal habeas review of a magistrate’s extradition certification, including review of treaty applicability and evidentiary sufficiency.
3. How to distinguish “pure” political offenses from “relative” political offenses in the setting of politically motivated violence by insurgent groups.

## Decision

- The Ninth Circuit reversed the district court’s grant of habeas relief.
- The court held the charged murder and London bombing conspiracies did not fall within the treaty’s political offense exception.
- The court concluded the magistrate properly certified extraditability because the magistrate had jurisdiction, the offenses were within the treaty, and the record contained evidence supporting probable cause.
- The habeas petition was denied, leaving extradition to proceed subject to the Secretary of State’s ultimate decision.

## Legal Principles

- In extradition, habeas review is narrow: the court examines (1) the magistrate’s jurisdiction, (2) whether the charged offense is covered by the treaty, and (3) whether there is any competent evidence supporting reasonable grounds (probable cause) to believe the accused committed the offense.
- The political offense exception generally covers “pure” political offenses (e.g., treason, sedition, espionage) and may cover “relative” political offenses only when common crimes are sufficiently incidental to and part of an uprising, rebellion, or comparable political disturbance.
- Political motivation alone is insufficient; modern doctrine construes the exception narrowly where the conduct resembles terrorist-type violence, particularly acts directed at civilians or otherwise outside a direct and close nexus to an uprising.

## Conclusion

The Ninth Circuit ruled that the alleged IRA-related murder of a London police officer and conspiracies to bomb in London were not protected political offenses under the U.S.–U.K. treaty and that habeas courts must apply a limited review of extradition certifications, thereby reinstating the magistrate’s certification and permitting extradition to proceed through the executive process.


Quinn v. Robinson, 783 F.2d 776 (9th Cir. 1986)