In the case of De La Rama v. De La Rama (1915), the U.S Supreme Court dealt with a dispute over property rights and inheritance laws between spouses. The plaintiff, Mrs. De la Rama, was seeking to recover her share from properties acquired during her marriage to Mr. De la Rama in the Philippines, which were then under American control following the Spanish-American War of 1898. She argued that according to Spanish law - which she claimed was still applicable - she had an equal right to these properties as they were purchased using marital funds. The court ruled against Mrs.De la Rama's claim stating that after America took control over Philippines post-Spanish-American war, it implemented its own legal system there including property and inheritance laws replacing existing Spanish laws; hence those should be applied instead of old Spanish civil codes. This ruling established a precedent for how foreign law is applied within territories controlled by United States: once US establishes jurisdiction over a territory it can implement its own legal systems superseding any pre-existing ones.

The dissenting opinion in the case of De La Rama v. De La Rama argued that the majority's decision to uphold a lower court ruling, which granted a divorce and divided property based on Philippine law, was incorrect. The dissenting justices believed that because both parties were domiciled in California at the time of their marriage and during most of their married life, California law should apply instead. They contended that applying Philippine law would be unjust as it did not provide for alimony or an equal division of property upon divorce unlike Californian laws. Furthermore, they disagreed with the majority's view about domicile being determined by physical presence alone; rather they asserted it must also include intent to remain indefinitely. Thus, according to them since Mrs de la Rama had no intention to permanently reside in Philippines her domicile remained in California where she had rights under its marital laws.