Carlos Alberto Yacaman Mezav.U.S. Attorney General, Et Al.
Honduras sought the extradition of Carlos Alberto Yacaman Meza, a Honduran national accused of killing a former government minister after a dispute over promised public-works contracts and money. A magistrate judge certified Yacaman as extraditable under the United States-Honduras treaty, and the district court denied habeas relief. Yacaman argued that the Convention Against Torture barred surrender, that the murder was a political offense excluded by the treaty, and that the treaty was no longer valid after a Honduran coup and change of administration. The Eleventh Circuit held that the torture claim was not ripe because the Secretary of State had not decided whether to surrender Yacaman and retained authority to address humanitarian concerns. The court deferred to the Executive’s determination that the treaty remained in force, reasoning that Honduras had changed administrations rather than become a successor state. It also held that the murder was motivated by avarice and revenge, not committed during or incident to a political uprising. The court vacated in part, affirmed in part, lifted the stay, and remanded to dismiss the torture claim.
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