UNITED STATES OF AMERICA v. EDGAR JAVIER BELLO MURILLO, a/k/a Payaso,
US Court of Appeals for the Fourth Circuit, King, June 14, 2016,
Jurisdiction – Extradition – Due Process – Trial of defendant in US for murder of DEA agent in Columbia did not offend due process, even where American interests were not specifically targeted

Brehm analysis to satisfy due process requires sufficient nexus between defendant and US so that applying statute would not be “arbitrary or fundamentally unfair.”

Not arbitrary to prosecute defendant where his actions “affected significant American interests” even if those interests were not intended to be affected by the defendant.

Not unfair to prosecute defendant as long as he was aware that “conduct was criminal and would subject them to prosecution somewhere,” even if they didn’t realize they would be prosecuted in the United States.

Victim’s status as an Internationally Protected Person is jurisdictional, does not require mens rea unless specifically required by Congress.