The courts have granted rights to non-citizens in the United States, not non-citizens outside the United States.
James Madison provides the rationale:
"Aliens are not more parties to the laws, than they are parties to the Constitution; yet it will not be disputed, that as they owe, on one hand, a temporary obedience, they are entitled, in return, to their protection and advantage."
While aliens within the United States owe temporary obedience to its laws and thus enjoy protections under the Constitution, aliens abroad do not.
Again, see United States v. Verdugo-Urquidez where the Supreme Court determined aliens abroad were found illegible for Fourth Amendment protection as they were not considered "the people."
James Madison provides the rationale:
"Aliens are not more parties to the laws, than they are parties to the Constitution; yet it will not be disputed, that as they owe, on one hand, a temporary obedience, they are entitled, in return, to their protection and advantage."
While aliens within the United States owe temporary obedience to its laws and thus enjoy protections under the Constitution, aliens abroad do not.
Again, see United States v. Verdugo-Urquidez where the Supreme Court determined aliens abroad were found illegible for Fourth Amendment protection as they were not considered "the people."