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While there is no statutory right to bail in international extradition proceedings,' in Wright v. Henkel,2 the Supreme Court recognized that the presence of "special circumstances" may render the grant of bail appropriate to one facing extradition to a foreign country.3 This acknowledgment by the Court in Wright over one hundred years ago spawned the development of a federal common law on the question of bail in international extradition proceedings.4 This Article, which is divided into three parts, examines the evolution of that law. First, and by way of background, the Article provides an overview of foreign requests for extradition. Next, the Article discusses the mechanics of international extradition hearings. Lastly, the Article analyzes the Supreme Court's ruling in Wright and examines the development of the federal case law regarding admission to bail in international extradition proceedings.

The Federal Common Law of Bail in International Extradition Proceedings