The recently rejuvenated presumption against the extraterritorial reach of U.S. laws applies to civil racketeering cases, a federal judge has ruled.

Applying the logic of the U.S. Supreme Court’s June decision limiting the reach of securities actions, Southern District Judge Jed S. Rakoff dismissed a civil Racketeer Influenced and Corrupt Organizations Act action alleging that individuals and entities affiliated with the Venezuelan government unjustly imprisoned a Venezuelan citizen and damaged his business.

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