Kashamu v. U.S. Dept. of Justice

Dist. Ct. did not err in dismissing plaintiff’s complaint under Mansfield Amendment, alleging that he was entitled to injunctive relief that would preclude defendant’s agents from colluding with Nigerian officials for purposes of abducting him on provisional warrant in order to stand trial on U.S. criminal charges. Dist. Ct. could properly base instant dismissal on its finding that Mansfield Amendment did not give plaintiff private cause of action. Moreover, plaintiff’s complaint failed on its merits, where: (1) plaintiff cited instance where Nigerian officials had attempted to arrest him on provisional warrant; and (2) Mansfield Amendment does not prohibit U.S. employees from actively participating in attempt by Nigerian agents to arrest him, as alleged in instant complaint.