On September 26, 1991, the Supreme Court of Canada ruled by four votes to three that the government could surrender Charles Chitat Ng to California without first asking for a promise that he would not be executed. Ng had been in Canadian custody for six years. Canada sent him south the same day, and one account has him on a flight to California within minutes of the judgment. The last step took no time at all. Everything before it had taken six years: a treaty clause, a minister’s decision, an appeal, a cabinet reference and a constitutional argument over whether a country that had given up the death penalty could deliver a prisoner to a state that had not.
Extradition is the least dramatic part of most murder prosecutions, a matter of warrants, governors' signatures and transport orders. When a suspect is wanted for many deaths and has crossed a border, it can become the whole case for years at a stretch. One jurisdiction holds the body; another holds the charge it most wants to try. The question of who goes first, and what punishment waits at the far end, has decided where serial suspects were tried, how long families waited, and in at least one case whether a second country could try a man at all.
Ng was born in Hong Kong, schooled partly in England and moved to the United States at 18. He served in the Marines. In 1984 and 1985 he was associated in Calaveras County with Leonard Lake, a survivalist and fellow former Marine. Lake was arrested in South San Francisco on June 2, 1985, and died in custody four days later; he was never charged with any killing. Ng went to Chicago and from there to Canada. He was arrested in Calgary on July 6, 1985, convicted in Canada of offenses arising from that arrest and sentenced to four and a half years, which Canadian authorities ruled he had to serve before any extradition.
The United States asked Canada to send him back to stand trial in California. Canada had abolished capital punishment in 1976, and its extradition treaty with the United States allowed it to refuse surrender unless it received assurances that a death sentence would not be imposed or carried out. No California official would give that assurance.
The courts moved in order. A judge of the Alberta Court of Queen’s Bench issued a warrant of committal on November 29, 1988. The Alberta Court of Appeal dismissed Ng’s appeal on May 2, 1989. The Minister of Justice then decided not to seek assurances. Ng’s Canadian lawyer, Donald MacLeod, kept fighting, and in 1990 the federal cabinet referred two questions directly to the Supreme Court: whether surrendering Ng without assurances would violate the Canadian Charter of Rights and Freedoms, and whether the minister’s decision could be challenged at all.
The court heard the reference on February 21, 1991, alongside the case of Joseph Kindler, an American who had escaped to Canada after being sentenced to death in Pennsylvania. California and Amnesty International were allowed to intervene. The answer to both questions was no. Justices La Forest and McLachlin wrote for the majority, each joined by Justices L’Heureux-Dube and Gonthier, and the majority described the crimes charged as nearly unspeakable. Justices Sopinka and Cory dissented, each joined by Chief Justice Lamer. One dissent observed that Ng also faced charges carrying no death penalty, among them attempted murder, kidnapping and burglary, so he would be extradited in any event; the only question was on what terms.
The assurance question did not end with the surrender. Ng had spent six years in Canadian custody, and the trial that followed in California would take almost eight more. The fight over the border had been decided by the body that acted first, and the body that acted first was the one holding the prisoner, a pattern that would recur.
The trial took even longer than the extradition. Ng first appeared in Calaveras County on September 27, 1991. The court declined to reappoint the two lawyers who had represented him before 1988, and he spent the following years trying to get them back; the California Supreme Court later counted 37 motions to replace appointed counsel, of which one was granted. The case was moved to Orange County in 1994 because of local publicity. Ng was allowed to represent himself in May 1998 and lost that right in August, when the court concluded he was using it to delay the trial.
On February 24, 1999, an Orange County jury convicted him of 11 counts of first-degree murder: six men, three women and two infant boys. It deadlocked on a twelfth count, for the death of Paul Cosner, which the judge dropped. Attorney General Bill Lockyer said the case had taken "nearly 14 years" of legal proceedings and "more than $11 million in public expenses." Ng was sentenced to death in Santa Ana on June 30, 1999. The California Supreme Court affirmed the sentence on July 28, 2022. In June 2026 the Lancashire Post reported that he had been moved from San Quentin to the California Medical Facility at Vacaville. California has carried out no execution since 2006, and Governor Gavin Newsom has imposed a moratorium. The promise Canada never asked for has, in practice, been kept by other means.
The Ng case turned on a death penalty that one side had and the other did not. Forty years earlier, the same difference had worked in the opposite direction, and inside a single country.
Raymond Martinez Fernandez, born in Hawaii to Spanish parents, met women through mail-order lonely hearts clubs. With Martha Beck, who posed as his sister, he took their money. On January 4, 1949, Janet Fay, a widow from Albany, New York, died in Valley Stream, on Long Island. Weeks later the couple were arrested in Michigan, near Grand Rapids, where police were inquiring after another widow, Delphine Downing. Statements the pair gave in Michigan turned the inquiry toward New York.
Both states could have prosecuted. New York had the death penalty, and Michigan did not, and published histories of the case give that as the reason the couple were sent east. A Nassau County grand jury indicted them for the first-degree murder of Janet Fay, the trial was moved to Bronx County, and in the summer of 1949 a jury convicted both of murder in the first degree. Under New York law at the time the sentence was death. Fernandez and Beck were executed in the electric chair at Sing Sing on March 8, 1951, Fernandez first. The New York State Archives lists them as prisoners 108595 and 108594.
No treaty was involved, only the ordinary machinery of interstate extradition. But the choice of forum was a choice of punishment, made openly, and it set the pattern for the American cases that followed.
Andrew Urdiales, a former Marine who had served in Southern California and later worked as a security guard in Chicago, was convicted of murdering eight women: five in Southern California between 1986 and 1995 and three in the Chicago area in 1996. He confessed to the Illinois killings on April 22, 1997, and told Chicago detectives there were matters in California that authorities there might want to hear about.
Illinois had him, and Illinois kept him. A Cook County jury convicted him of the murders of Laura Uylaki and Lynn Huber, and he was sentenced to death on September 3, 2002. Governor George Ryan commuted every death sentence in the state in January 2003, and Urdiales’s became natural life. Livingston County then tried him for the murder of Cassandra Corum; on May 10, 2004, the judge rejected his plea of guilty but mentally ill and his insanity defense and convicted him of first-degree murder, and a jury sentenced him to death again. The Illinois Supreme Court reviewed that case in 2007.
California waited. On August 5, 2009, the Orange County District Attorney’s Office charged him with five counts of special-circumstances murder, after prosecutors in Orange, Riverside and San Diego counties agreed to combine the cases. An Orange County grand jury indicted him on December 14, 2009. Senior Deputy District Attorney Howard Gundy told the Hi-Desert Star he was looking for a window to bring Urdiales west that would not interrupt the Illinois proceedings, and prosecutors said he would come after the evidentiary part of his Illinois death penalty appeal ended.
The window came from Springfield. In March 2011 Governor Pat Quinn signed a bill abolishing the death penalty in Illinois and commuted the sentences of the 15 men on its death row, Urdiales among them. Within hours, CBS Chicago reported, Orange County prosecutors began seeking his extradition. Jim McKay, the former Cook County prosecutor, called the situation a joke and offered to help get him to California, and Orange County asked Governor Jerry Brown to seek Quinn’s help. Urdiales was taken from the Pontiac Correctional Facility in late September or early October 2011, and that October Orange County announced it would seek death.
The trial did not open until 2018. On May 23 a jury convicted him on all five counts, and on October 5, 2018, Judge Gregg Prickett imposed five consecutive death sentences, so that each would stand alone if any other fell. Urdiales was received at San Quentin on October 12. He died in his cell there on November 3, 2018, and prison officials investigated the death as a suicide. District Attorney Tony Rackauckas said he had denied the families the chance to see him executed. Illinois’s abolition had not spared him a death sentence. It had sent him to the state that could still impose one.
Glen Edward Rogers, from Hamilton, Ohio, was convicted of murdering Sandra Gallagher, 33, in Los Angeles in September 1995 and Tina Marie Cribbs, 34, in Tampa that November. He was arrested in Kentucky on November 13, 1995. Both states had capital punishment, so the contest between them was over order, not outcome.
Florida charged him first, indicting him in Hillsborough County on December 13, 1995, for first-degree murder, robbery with a weapon and grand theft of a motor vehicle. The two states agreed that he would be tried in Florida and then sent to California. He was sentenced to death in Florida on July 11, 1997, and California indicted him for Gallagher’s murder and for arson two days earlier, on July 9.
Rogers resisted the second trip. A habeas petition he brought in Bradford County, Florida, was denied in December 1997, and the Florida Supreme Court affirmed the extradition ruling on May 14, 1998. He was extradited in October 1998. In Los Angeles County Superior Court a jury convicted him on June 22, 1999, and returned a true finding on the special circumstance of a prior first-degree murder conviction. The prior conviction was the Florida verdict; the first state’s judgment had become an element of the second state’s case. He was sentenced to death on July 16, 1999, and returned to Florida that August.
The Florida Supreme Court affirmed his death sentence in 2001, and the California Supreme Court affirmed the California judgment on July 25, 2013. Florida was the state that acted. Governor Ron DeSantis signed a death warrant on April 15, 2025, and Rogers was executed by lethal injection at Florida State Prison near Starke on May 15, 2025. He was 62.
Sometimes the jurisdiction with the older claim simply has to stand in line. Tricia Pacaccio, 18, a recent graduate of Glenbrook South High School, was killed in Glenview, Illinois, in August 1993, about a week before she was to leave for Purdue University. Michael Gargiulo, who lived about a block from her family and was a friend and classmate of her brother, was considered at the time, but investigators did not have enough to charge him. He moved to the Los Angeles area.
In Los Angeles he was convicted of the first-degree murders of Ashley Ellerin, 22, in February 2001 and Maria Bruno, 32, in December 2005, and of the attempted murder of a woman in Santa Monica in 2008, who survived. Santa Monica police arrested him on June 6, 2008. Illinois investigators had linked him to the Pacaccio case through a DNA comparison in 2003, but no charge followed for years. In May 2011 the CBS program 48 Hours aired an episode on the case. Two former co-workers from a Hollywood nightclub then came forward to say he had spoken to them of killing a girl in Chicago, and on July 7, 2011, Cook County charged him with first-degree murder.
That charge could not move while California held him. The Los Angeles trial did not open until May 2019. The jury convicted him on August 15, 2019, and after delays from procedural issues and the pandemic Judge Larry P. Fidler sentenced him to death on July 16, 2021. A California death judgment carries an automatic appeal to the state supreme court, and no decision had been reported by October 2026.
After the 2019 verdict, the Cook County State’s Attorney’s Office said it would seek his extradition. Her brother told ABC7 Chicago that the Los Angeles verdict did not feel finished. Gargiulo was extradited on September 5, 2024, and appeared in the Skokie courthouse the next day, aged 48, walking with a cane. Judge Anthony Calabrese denied pretrial release. On September 30, 2026, CBS Chicago reported that he had appeared by Zoom for a status hearing, that his lawyers were reviewing the evidence and that he was due back in court on November 11. No trial date had been set. He denies the Pacaccio killing, and in Illinois it is a charge, not a conviction. A man under sentence of death in one state was sent to another to answer for a killing 31 years old, and the transfer itself took five years after the verdict that made it possible.
Not every delay is a matter of principle. Sean Lannon, a former Army soldier living in Grants, New Mexico, was arrested in St. Louis on March 10, 2021. He was charged that day in Gloucester County, New Jersey, with the murder of Michael Dabkowski, 66, and sent there. New Mexico charged him later that month with murder in the deaths of his former wife, Jennifer Lannon, 39, and two of her friends, Jesten Mata, 40, and Matthew Miller, 21, in Grants, and later with the murder of Randal Apostalon, 60, in Albuquerque.
New Jersey went first. Lannon pleaded guilty to first-degree murder in October 2022 and was sentenced to 35 years in state prison, with parole eligibility after 30. Two New Mexico district attorneys' offices said they meant to bring him back.
On January 10, 2023, a Cibola County magistrate issued a warrant for his extradition. Then the hearings stalled. He was to be arraigned by video on April 7, 2023, but was never connected, because no one had allowed for the time difference between New Mexico and New Jersey, the Cibola Citizen reported. On May 1 he again failed to appear, and defense lawyers said officials in New Jersey had not been communicative. On June 5 he missed a third video hearing, and District Judge Amanda Sanchez Villalobos ordered the next one held in person. The court let the Albuquerque case carry the extradition paperwork, since that court was already bringing him back.
He was returned to New Mexico in June 2023. At his Albuquerque arraignment his lawyer said he would "stand silent as to a plea," and the judge entered a plea of not guilty for him. In May 2024 the Albuquerque Journal reported that he had agreed to plead guilty to second-degree murder in all four New Mexico deaths, 15 years for each, 60 years in all. Under the agreement, the Journal reported, he would serve the New Jersey term first. As of May 2024 he was held at the Metropolitan Detention Center in Albuquerque.
In Europe the instruments are different and the timetable often shorter. Bartolomeo Gagliano, a man of Sicilian origin from Savona, was never convicted of murder. Italian courts declared him totally insane and committed him to judicial psychiatric hospitals for three killings, one near Savona in 1981 and two near Genoa in 1989. By 2013 he was in Genoa’s Marassi prison serving time for robbery and extortion. In December of that year he failed to return from a good-conduct leave, and the case set off a national political row.
He was arrested in Menton, just across the French border, on December 20, 2013, by French special units from Nice working with Interpol. France dealt with him first on its own account: on December 24, 2013, a court in Nice sentenced him to ten months for carrying a gun and holding false identity papers, and he spent about four months in a specialist medical center. On April 23, 2014, the appeal court at Aix-en-Provence granted Italy’s extradition request. ANSA reported that he had by then been declared mentally ill and still had to serve the rest of his 2006 extortion sentence, and that he spat at reporters as he was brought back across the border at Ventimiglia.
On January 14, 2015, judges in Genoa sentenced him to six years and ten months for the escape, the kidnapping of a delivery driver and armed car theft. Eight days later the authorities announced that he had died by suicide in his cell. From arrest to surrender the French proceeding had taken four months, a fraction of the Canadian one. No death penalty stood at either end, and two neighboring states inside one legal order had little to argue about.
Extradition can also be refused because the requesting country is too late in a different sense: the person has already been tried. Luis Alfredo Garavito, born in Genova, Quindio, in 1957, was arrested near Villavicencio, Colombia, on April 22, 1999, and convicted in Colombia of homicide, with other charges, in well over a hundred cases involving children. His sentences were reported as adding up to 1,853 years, held to the 40-year legal maximum.
Several of the deaths were in Ecuador. Ecuadorian judicial police reported on the killings in January 2001, and courts in Pichincha opened proceedings for asesinato, aggravated murder, over boys killed in Santo Domingo de los Colorados in July 1998. Colombia moved on the same facts. On October 23, 2006, prosecutors in Pereira charged Garavito with four killings in Ecuador, two in Santo Domingo de los Colorados and two in Chone, and on July 6, 2007, a Pereira circuit court convicted him of aggravated homicide, with other charges. The sentence was 266 months and 20 days, final that September.
Ecuador asked for his extradition by diplomatic note on May 12, 2011, to try him once he finished his Colombian sentence. Semana reported that Colombian prosecutors ordered his arrest for extradition purposes, and Ecuador’s ambassador, Raul Vallejo, welcomed the step. On May 23, 2012, the Criminal Cassation Chamber of Colombia’s Supreme Court of Justice issued an unfavorable opinion. It accepted that the formal requirements were met but held that the acts were res judicata under the Bolivarian Extradition Agreement of 1911, because Colombia had already tried him for them. Whether Ecuador ever convicted him is unsettled: El Comercio of Quito reported a 22-year sentence there, but the Colombian court’s 2012 opinion follows the Ecuadorian case only to the opening of trial in 2008 and mentions no judgment. Garavito died in custody in Valledupar on October 12, 2023, still in Colombia.
Charles Sobhraj, a French citizen born in Saigon in 1944, spent much of his adult life in the gap between jurisdictions. Police linked him to a series of deaths of young Western travelers in Thailand, Nepal and India in the mid-1970s. He was arrested in New Delhi on July 5, 1976, and held in India, including after a 1986 escape and recapture, until 1997, when he was released and sent to France.
Thailand wanted him. India had reportedly agreed in 1985 to extradite him to Thailand for two of the deaths there, but India held him first, and by the time it let him go the Thai case was gone. John McBeth, writing in Asia Times, says the Thai arrest warrant had expired before the 1997 release; Agence France-Presse says the alleged crimes had passed the statute of limitations. The reported dates of the lapse vary between 1995 and 1996. In 2022 Sompol Suthimai, the Thai officer who had pressed for his extradition, told AFP at 90 that he did not object to Sobhraj’s release because he "has already paid for his actions." The deaths in Thailand are attributed to him and were never tried.
Nepal’s cases had never closed. Sobhraj went back to Kathmandu in 2003 and was arrested there that September; The Himalayan Times dates the arrest September 19. A Kathmandu court convicted him on August 12, 2004, of the 1975 murder of Connie Jo Bronzich, an American, and the Supreme Court of Nepal upheld the life sentence on July 30, 2010, after an appeal that had run for more than four years. In 2014 a Nepali court convicted him of the 1975 murder of Laurent Carriere, a Canadian.
The final transfer ran the other way, out of the prosecuting country. On December 21, 2022, a division bench of the Supreme Court of Nepal ordered his release on a habeas corpus petition. It held that prison rules allowing prisoners over 65 up to 75 percent remission of sentence applied to foreigners, noted that he had served 95 percent of his 20-year term, and ordered him sent to his own country within 15 days unless another case required him. He was released on December 23, 2022, after 19 years, three months and seven days, taken to the airport under police escort and put on a flight to Paris that evening. The Nepali government barred him from the country for ten years. At Charles de Gaulle the next morning, border police checked his identity and let him go. In an interview in Paris published in August 2023, he said he had never killed anybody.
Read together, these cases suggest that the law of extradition rarely decides guilt and very often decides everything around it. Canada’s treaty clause did not save Charles Ng from a death sentence; it bought him six years in a Canadian cell and a constitutional ruling that went against him. Illinois’s abolition did not save Andrew Urdiales from death row; it removed the reason to keep him. New York took Fernandez and Beck in 1949 for the same reason Orange County took Urdiales in 2011.
Between states that share a punishment, the fight is over sequence. Florida tried Glen Rogers first and executed him last. California tried Michael Gargiulo first, and the family in Glenview waited 13 years after the Illinois charge for him to be brought there, and is still waiting for a trial. In New Mexico, video hearings that never connected held up four murder cases for months.
Across national borders, the strongest defenses were sometimes procedural ones. Colombia refused Ecuador because it had already convicted Garavito on the same facts. Thailand lost Sobhraj to a lapsed warrant while India held him. France, by contrast, handed Bartolomeo Gagliano back in four months. The prisoner in each case was the same kind of prisoner. What differed was the paper, and the order in which each government chose to read it.
• January 4, 1949: Janet Fay dies in Valley Stream, New York.
• Early 1949: Raymond Fernandez and Martha Beck arrested in Michigan; sent to New York to stand trial.
• March 8, 1951: Fernandez and Beck executed at Sing Sing.
• July 5, 1976: Charles Sobhraj arrested in New Delhi.
• June 2, 1985: Leonard Lake arrested in South San Francisco; dies in custody June 6.
• July 6, 1985: Ng arrested in Calgary.
• November 29, 1988: Alberta court issues warrant of committal for Ng.
• 1990: Federal cabinet refers the Ng questions to the Supreme Court of Canada.
• September 26, 1991: Supreme Court of Canada rules 4 to 3; Ng extradited the same day.
• April 8, 1994: Charles Ng’s case moved from Calaveras County to Orange County.
• November 13, 1995: Glen Edward Rogers arrested in Kentucky.
• 1997: Sobhraj released by India and sent to France; the Thai case has lapsed.
• April 22, 1997: Andrew Urdiales confesses to three Illinois killings.
• May 14, 1998: Florida Supreme Court affirms the ruling allowing Rogers’s extradition to California.
• October 1998: Rogers extradited to California.
• February 24, 1999: Ng convicted of 11 counts of first-degree murder.
• April 22, 1999: Luis Alfredo Garavito arrested near Villavicencio.
• June 22, 1999: Rogers convicted in Los Angeles; sentenced to death July 16.
• September 3, 2002: Urdiales sentenced to death in Cook County; commuted in January 2003.
• September 2003: Sobhraj arrested in Kathmandu.
• August 12, 2004: Sobhraj convicted in Nepal of the murder of Connie Jo Bronzich.
• July 6, 2007: Garavito convicted in Pereira for four killings in Ecuador.
• June 6, 2008: Michael Gargiulo arrested in Santa Monica.
• August 5, 2009: Orange County charges Urdiales with five murders.
• July 30, 2010: Supreme Court of Nepal upholds Sobhraj’s life sentence for the Bronzich murder.
• March 2011: Illinois abolishes the death penalty; Orange County seeks Urdiales’s extradition within hours.
• May 12, 2011: Ecuador requests Garavito’s extradition.
• July 7, 2011: Cook County charges Gargiulo with the murder of Tricia Pacaccio.
• Late September or early October 2011: Urdiales extradited to California.
• May 23, 2012: Colombia’s Supreme Court issues an unfavorable opinion on Ecuador’s request.
• December 20, 2013: Bartolomeo Gagliano arrested in Menton, France.
• April 23, 2014: Aix-en-Provence appeal court grants Italy’s request for Gagliano.
• January 22, 2015: Gagliano’s death in prison announced.
• May 23, 2018: Urdiales convicted in Orange County; sentenced to death October 5; dies November 3.
• August 15, 2019: Gargiulo convicted in Los Angeles; sentenced to death July 16, 2021.
• March 10, 2021: Sean Lannon arrested in St. Louis.
• July 28, 2022: California Supreme Court affirms Ng’s death sentence.
• October 2022: Lannon pleads guilty in New Jersey; sentenced to 35 years.
• December 23, 2022: Sobhraj released and deported from Nepal to France.
• January 10, 2023: Cibola County issues an extradition warrant for Lannon.
• June 2023: Lannon returned to New Mexico.
• October 12, 2023: Garavito dies in custody in Valledupar.
• May 2024: Lannon agrees to plead guilty in New Mexico to four counts of second-degree murder.
• September 5, 2024: Gargiulo extradited to Illinois.
• May 15, 2025: Rogers executed in Florida.
• November 11, 2026: Gargiulo’s next scheduled Cook County court date.