The issue can also arise in the context of statutory interpretation. For instance, Justice Thurgood Marshall argues in his dissent to EEOC v. Aramco that the presumption against extraterritoriality is rebutted by a negative inference from the alien-exemption provision of Title VII of the Civil Rights Act of 1964, which states that Title VII "shall not apply to an employer with respect to the employment of aliens outside any State."
The issue can also arise in the context of statutory interpretation, specifically regarding extraterritoriality. Justice Thurgood Marshall argues against the presumption against extraterritoriality in his dissent to EEOC v. Aramco, citing a negative inference from Title VII's alien-exemption provision.