# Johnson v. Eisentrager **Status: stub — expand.** Vote counts to be verified against Oyez before they are stated here. The Court held that enemy aliens held **outside** U.S. sovereign territory — German nationals convicted by military commission in China and imprisoned in occupied Germany — had no right to petition U.S. courts for habeas corpus. **Why it matters:** the doctrinal foundation of the "law-free zone" theory. If the writ follows sovereign territory rather than the jailer's custody, an offshore prison is beyond judicial reach. That reading governed until [[Rasul v. Bush]] distinguished it in 2004 and [[Boumediene v. Bush]] rejected it as a formal territorial test in 2008. ## See Also - [[Habeas Corpus Timeline]] · [[Habeas Corpus]] · [[Suspension Clause]]