Much has already been written about the Roberts Court and its jurisprudential direction, particularly in light of the perceived conservative leanings of five of the justices (now four, after the passing of Justice Antonin Scalia). One discernible trend concerns the “extraterritoriality” of U.S. statutes, i.e. whether U.S. laws apply to events occurring abroad.

The Roberts Court has tended to rule against extraterritorial application. The latest decision, RJR Nabisco v. European Community, continues this trend. But given the present composition of the court, and the closeness of the vote in the case, this may be the last in the line.