Considerable interest was aroused by the press announcement of October 4, 1932, that Samuel Insull, former utilities magnate, had been indicted by an Illinois grand jury on charges of embezzlement and larceny and that his extradition from France, where he was then sojourning, would be requested. The seventy-four year old fugitive displayed unusual vigor in surreptitiously leaving Paris by train for Italy, where he boarded an airplane for Greece. He arrived in Athens on October 9, 1932, just one day after the request for his extradition reached Paris. On the following day he was arrested by the Greek authorities on request of the United States Legation at Athens, to be held pending proceedings for extradition. He was released a day later, however, because at that time there was no extradition treaty in force between Greece and the United States and no proper warrant for his detention had been issued. In order to prevent his escape again, the United States Legation was directed to recapture Insull's passport, thus virtually making him a prisoner in Greece. This he resisted, claiming that it was, in effect, a cancellation of his citizenship. Press dispatches of January 14, 1933, indicate that this cancellation has taken place. As a matter of fact, an extradition treaty had been signed on May 6, 1931, between Greece and the United States, its ratification had been advised by the United States Senate on February 19, 1932,2 the treaty had been proclaimed by the President of Greece on October 2, 1932, and had become effective by formal exchange of ratifications at Washington on November 1, 1932. Insull was provisionally arrested under the terms of this treaty on November 4, 1932, and his arrest was sustained by the Court of Appeals at Athens, despite his objection that the treaty could not operate retroactively. On November 21 the case was suspended until the arrival in Athens of the necessary documents. On December 27, 1932, after a full hearing, the Greek Court of Appeals refused to approve the extradition of Insull.