The World in U.S. Courts: Summer and Fall 2016 - Anti-discrimination Statute, 42 USC § 1981
Salem, an American citizen, and his Moroccan wife alleged that they were the targets of racially and religiously discriminatory conduct by representatives of Royal Air Maroc as they sought to board a flight from Cairo to Casablanca. Salem sued the airline upon his return to the U.S. Claiming violations of Section 1981. The Court dismissed the case, concluding that the statute only reached covered discriminatory conduct within the “territorial jurisdiction” of the U.S., and was not to be given extraterritorial effect.