This Comment argues that United States v. Verdugo-Urquidez signals an unwarranted limitation on constitutional protections which may present disturbing ramifications for aliens in U.S. courts. Part I of this Comment examines the line of cases that extend constitutional protections to citizens beyond U.S. borders and to aliens within U.S. territory. Part II discusses the factual and procedural background of the Verdugo-Urquidez case. Part III discusses the reasoning of the plurality, concurring, and dissenting opinions. Part IV analyses the plurality opinion and suggests that United States v. Verdugo-Urquidez reverses a trend extending constitutional protection outside the United States. This Comment concludes that Verdugo-Urquidez may foreshadow a limitation of constitutional protections for new classes of individuals.
Mary Lynn Nicholas,
United States v. Verdugo-Urquidez: Restricting the Borders of the Fourth Amendment,
14 Fordham Int'l L.J. 267
Available at: http://ir.lawnet.fordham.edu/ilj/vol14/iss1/12