US citizen loses extradition appeal for sentencing on child abuse material

The Court of Appeal has rejected an argument by a US man that his fundamental rights would be breached due to “over-detention” in the state of Louisiana if he was extradited back to his home country to be sentenced for possessing child abuse material.

Judge Paul Burns said John Patrick Navarro (37) had failed to establish a real risk that his fundamental rights would be breached if he was surrendered.

On Thursday the Court of Appeal affirmed a High Court order for the appellant to be extradited.

He is wanted for sentencing on 11 counts in relation to the possession of pornography involving juveniles.

He had pleaded guilty to the offences on February 6th, 2018, in the Criminal District Court for the parish of Orleans, Louisiana.

After pleading guilty, Navarro was granted bail and his case was listed for sentencing in February 2018. However, he failed to appear.

The US issued an extradition request to the Irish authorities in December 2024 and Navarro was brought before the High Court the following April.

His surrender was ordered by Judge Sean Gillane in July 2026.

Appealing that in October, Navarro’s barrister, Mark Lynam, said the focus of the extradition proceedings had been over-detention in Louisiana, where he said prisoners were systematically being held for longer than they should have been as a result of “defects in the system”.

He contended that Gillane erred when assessing the risk of a breach of his client’s rights if surrendered.

The barrister pointed to an expert report from Andrea C Armstrong, a professor of law at Loyola University, New Orleans, which highlighted a number of ongoing cases aimed at preventing prisoners from being over-detained. Counsel said there was also a class-action lawsuit in Louisiana challenging over-detention, which he said remained a “live issue”.

However, Ronan Kennedy, barrister for the Attorney General, said the judge had not simply accepted the assurance provided but rather had engaged in a “detailed, factual analysis”. He said the judge carried out a rigorous examination of all the material and information before him in accordance with the law.

In delivering the court’s judgment on Thursday, Burns said he could find no fault in the manner in which the High Court judge approached this issue or in the determination arrived at by him.

The judge said there was a default presumption that the other country would act in good faith and that it would respect fundamental rights.

Burns said the High Court judge received information as to the considerable and detailed measures that had been put in place to deal with the issue of over-detention in Louisiana.

The court dismissed the appeal and a stay was put on the order for 15 days to allow the appellant lodge an appeal with the Supreme Court.