This year marks 70 years since the end of the Nazi genocide of Europe’s Jews. The passage of time has largely halted prosecutions of those who perpetrated the crimes of the Holocaust. In the United States, the determined effort to expel Nazi perpetrators that began in 1979 has concluded. Its last chapter concerned an Auschwitz guard whose extradition Germany sought but who died this past July.1

American judicial proceedings against Johann Breyer involved a confluence of historically significant circumstances—a collision between expanding constitutional doctrine and America’s commitment to expel Nazi perpetrators, echoes of the post-war Nuremberg tribunals, and a reference point to gauge Germany’s evolving commitment to prosecute Nazi criminals. It is singularly fitting that the denouement of America’s 35-year effort was infused with much historical resonance.