In the 1920 case Ex Parte in the Matter of Hussein Lutfi Bey, Master of The Gul Djemal, Petitioner, a Turkish ship named "The Gul Djemal" was seized by U.S. authorities while docked at an American port during World War I due to suspicions that it carried materials intended for Germany's war efforts. After Turkey signed an armistice with Allied Powers and diplomatic relations were restored between Turkey and the United States, Hussein Lutfi Bey petitioned for release of his vessel on behalf of its owners. However, he faced opposition from creditors who had claims against the ship’s cargo. The Supreme Court ruled that since there was no formal declaration of war between America and Turkey during WWI (despite severed diplomatic ties), seizure laws applicable in times of declared wars did not apply here. Therefore, they ordered return of the ship to its owners but allowed creditors' claims against it to proceed under normal legal process rather than wartime rules.

In the dissenting opinion for Ex Parte in the Matter of Hussein Lutfi Bey, Master of The Gul Djemal case, Justice Oliver Wendell Holmes Jr. disagreed with the majority's decision to deny habeas corpus relief to a Turkish shipmaster who was detained by U.S. authorities during World War I. He argued that international law did not provide sufficient grounds for his detention and that he should be released immediately as there were no charges against him under domestic law either. Holmes also pointed out inconsistencies in applying wartime laws and regulations, suggesting an arbitrary application of justice which he found unacceptable. Furthermore, he emphasized on individual rights over state power especially during times when civil liberties are most at risk - such as war time.