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MS-13 members often have lots of tattoos. Some are even on the face and neck. Yuck.

Mr. Garcia Kilmar Abrego Garcia has MS-13 tattoos. On April 4, 2025, U.S. District Judge Paula Xinis ordered the Trump Administration to try to bring Mr. Garcia back to the Maryland, to her court, from his jail in El Salvador.

Under long-established international law, nation-states have jurisdiction over their citizens wherever they are. That jurisdiction can sometimes be concurrent with the jurisdiction of another nation-state, but the nation-state still has jurisdiction over its citizens even when they live overseas. In international law, this is called the Nationality Principle.

The Nationality Principle is the basis for subjecting wealthy Americans to U.S. tax law even when they live overseas. That‘s why some wealthy Americans move abroad and give up their U.S. citizenship.

Mr. Garcia is a Salvadoran citizen. He remained a Salvadoran citizen when he lived in Maryland as an illegal alien. El Salvador has primary jurisdiction over Mr. Garcia, not Judge Xinis. Legally, this is a no-brainer.

Unfortunately for Mr. Garcia, El Salvador outlawed MS-13 membership, and the Salvadoran government is locking up MS-13 members. Since the crack down, drug dealing and violent crime have dropped significantly in El Salvador.

If you are an MS-13 member, you might want to cover up that tattoo.

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