In Hilton v. Guyot (1894), the US Supreme Court ruled that judgments rendered in foreign nations are not automatically enforceable in the United States, but rather they should be subject to examination and potential re-litigation. The case involved a dispute between American ship-owners and French merchants over unpaid freight charges. When French courts ruled in favor of the merchants, they sought enforcement of their judgment in America. However, the Supreme Court held that while comity - respect for another nation's laws - often leads to recognition of foreign judgments, it is not an absolute obligation under international law or U.S constitution; instead it depends on reciprocity from other countries' legal systems towards U.S judgements as well as fairness considerations within each individual case.

In the dissenting opinion for Hilton v. Guyot, Justice Brewer argued that international law should be applied in this case and not domestic French law. He believed that the majority's decision was based on a misunderstanding of foreign judgments' recognition under international law principles. According to him, it is an established principle of public policy to recognize and enforce foreign judgments unless they are contrary to justice or prejudicial interests. The refusal by American courts to enforce French court decisions would only lead France reciprocally refusing enforcement of American court rulings, which could potentially harm U.S citizens with valid claims in France. Thus he disagreed with the majority’s view that reciprocity must be legislatively mandated before being judicially enforced.