In the 1923 case Davis, as Agent of the President, etc. v. Slocumb, Administratrix of Slocumb, the U.S Supreme Court was tasked with determining whether or not a suit against an agent of the president could be considered a suit against the United States itself. The plaintiff in this case sought to recover damages for property taken by military authorities during World War I under orders from then-President Woodrow Wilson's appointed representative (Davis). The court ruled that such suits were indeed suits against the U.S., and thus they fell under sovereign immunity - meaning that they couldn't proceed without consent from Congress. This decision essentially established that actions taken by agents on behalf of presidents are protected under sovereign immunity laws.

In the dissenting opinion for Davis v. Slocumb, Justice Holmes disagreed with the majority's decision to reverse a lower court ruling that had allowed an administrator of an estate to recover damages from a federal agent who had seized property without due process during World War I. He argued that the case should have been dismissed because it was not within the jurisdiction of federal courts as it involved state law claims against a federal officer acting under color of his office. Furthermore, he contended that even if there were grounds for recovery under state law, they would be precluded by sovereign immunity since any judgment would effectively be against the United States government which cannot be sued without its consent. Finally, he expressed concern about potential implications on public administration and warned against allowing individuals to sue government officials personally for actions taken in their official capacity.