The U.S. Supreme Court case Fraenkl v. Cerecedo Hermanos in 1909 involved a dispute over the payment of a debt between two international parties, one based in New York and the other in Mexico City. The plaintiff, Mr. Fraenkl, argued that he had made an agreement with the defendants (Cerecedo Hermanos) to pay off their debt through installments but they failed to do so despite his repeated requests for payment. The defendants claimed that there was no such agreement and refused to pay back any money owed on this basis. The court ruled against Mr.Fraenkl stating that while it is true that he did have some sort of understanding or arrangement with Cerecedo Hermanos regarding repayment of their debts, it does not constitute as a legally binding contract under Mexican law which governs this particular transaction due to its location at time of inception. Therefore, since there was no formal written contract signed by both parties agreeing upon terms for repayment schedule or interest rates etc., then technically speaking according to Mexican law - no legal obligation exists on part of Cerecedo Hermanos towards repaying said debts hence they cannot be forced into doing so either.

The dissenting opinion in the case of Fraenkl v. Cerecedo Hermanos argued that the majority's decision was inconsistent with previous rulings and principles of international law. The dissent contended that, under established legal precedent, a foreign judgment should be recognized and enforced unless it is shown to be unjust or contrary to public policy. In this case, there was no evidence presented to suggest that the Spanish court's ruling was unfair or violated any fundamental principles of justice. Therefore, according to the dissenting justices, there were no grounds for refusing to enforce it in U.S courts. They also pointed out inconsistencies between this decision and earlier Supreme Court cases involving similar issues which had upheld foreign judgments without requiring proof of reciprocity from other countries' courts.