In the case of Equitable Trust Company, Trustee v. Rochling et al., 1927, the U.S Supreme Court was tasked with determining whether a German corporation could be sued in New York for damages incurred during World War I. The plaintiff, Equitable Trust Company (acting as trustee), argued that they had suffered losses due to actions taken by the defendant's company during wartime and sought compensation. However, the defendants contended that since their corporation was based in Germany and not directly involved in any activities within New York State or even America at large during this period, it should not be subject to litigation there. The court ruled against Equitable Trust Company stating that while corporations are often treated as 'persons' under law for certain purposes such as contract enforcement or property ownership rights; they do not possess all attributes of personhood - specifically those related to jurisdictional presence necessary for legal proceedings like lawsuits. Thusly concluding that a foreign entity cannot be held accountable under American laws unless it has some form of substantial connection or activity within its territory.

In the dissenting opinion for Equitable Trust Company, Trustee v. Rochling et al., Justice Holmes disagreed with the majority's decision to dismiss the case on jurisdictional grounds. He argued that while it was true that a federal court could not issue an injunction against state proceedings in this instance, it did have jurisdiction over cases involving property rights and trusts as they fell under diversity jurisdiction. The fact that some of the parties involved were foreign citizens should not preclude them from seeking relief in U.S courts if their property rights were being violated. Furthermore, he contended that there was no need to wait until after state proceedings had concluded before filing suit in federal court because doing so would only delay justice and potentially cause further harm to those whose rights were being infringed upon.