[William S. Dodge is a Professor of Law at the University of California, Hastings College of the Law. One of his articles on
extraterritoriality was cited in Justice Stevens’s concurring opinion.] There is no doubt that Morrison v. National Australia Bank is a landmark opinion, not just because the Supreme Court addresses here, for the first time, the
extraterritorial reach of U.S. securities law, but also for what the opinion tells us more generally about the presumption against
extraterritoriality. As Margaret Sachs has already recounted, the Courts of Appeals, under...