Valentine v. United States, 299 U.S. 5 (1936), is known in the study of international criminal law for its contribution to the concept that while it is permissible for the United States to receive an accused without a treaty-based extradition, the United States itself will not extradite without authority found in statute or treaty. Article V of the Treaty of 1909 stated that “Neither of the contracting Parties shall be bound to deliver up its own citizens or subjects under the stipulations of this convention.”