In 2005, the U.S. Attorney's Office in Seattle looked into the possibility of bringing charges against Priven for the murder, but concluded that he could not be tried in any jurisdiction in the U.S. Although a 1994 law allows prosecutors to bring charges against an American citizen who kills another American citizen while overseas, and the PATRIOT Act allows U.S. Courts to try Americans for crimes they may have committed while overseas, neither of these laws were in effect in 1976 and they cannot therefore be applied retroactively to the Gardner murder case.