the FBI on 28 June 1983. Doherty was imprisoned in the Metropolitan Correctional Center in Manhattan, and a legal battle ensued with the British government seeking to extradite him back to Northern Ireland. Doherty claimed he was immune from extradition as the killing of Westmacott was a political act, saying "It was an operation that was typical of all operations where we set up an ambush of a British military convoy... It is a war, and this was a military action". He cited Article 5(1)(c)(i) of the 1972 U.S.-UK Extradition Treaty, which provided that: "Extradition shall not be granted if ... the offense for which extradition is requested is regarded by the requested Party as one of a political character". In December 1984, Sprizzo ruled that under the existing treaty, Doherty could not be extradited as the killing of a British soldier engaged in active combat was a "political offense" and his actions did not involve violence against civilians, including government representatives. In his finding, Spizzo wrote the political offense exception was extended to guerilla warfare in addition to "actual armed insurrections or more traditional and overt military hostilities". He also wrote that the IRA "has both an organization, discipline, and command structure that distinguishes it from more amorphous groups such as the Black Liberation Army or the Red Brigade." Spizzo also wrote that not every act constituted political offense: How then is the political exception doctrine to be construed and what factors should limit its scope? Not every act committed for a political purpose or during a political disturbance may or should properly be regarded as a political offense. Surely the atrocities at Dachau, Aushwitz, and other death camps would be arguably political within the meaning of that definition. The same would be true of My Lai, the Bataan death march, Lidice, the Katyn Forest Massacre, and a whole host of violations of international law that the civilized world is, has been, and should be unwilling to accept. Indeed, the Nuremberg trials would have no legitimacy or meaning if any act done for a political purpose could be properly classified as a political offense. Moreover, it would not be consistent with the policy of this nation as reflected by its participation in those trials, for an American court to shield from extradition a person charged with such crimes. The Court concludes therefore that a proper construction of the Treaty