On March 12, the Seventh Circuit ruled that Article 36 of the Vienna Convention grants private rights to aliens who are in the United States from countries party to the Convention. The opinion noted that, unlike the Fifth and Sixth Circuits, the Seventh Circuit does not regard the Convention’s Preamble as capable of creating ambiguity in the otherwise plain language of the article. The case is Jogi v. Voges, 2007 U.S. App. LEXIS 5713.