In the Howard v. De Cordova case of 1899, the U.S. Supreme Court was asked to determine whether a Jamaican property owner could sue in American courts for damages caused by an American citizen who had trespassed and cut down trees on his land while he was living in Jamaica. The defendant argued that since Jamaica was a British colony at the time, its laws should apply and therefore prevent such lawsuits from being filed in U.S. courts. However, the court ruled against this argument stating that international law allows individuals to seek redress for wrongs committed against them regardless of where they occur or where they live when seeking justice.

In the dissenting opinion for Howard v. De Cordova, Justice Harlan argued that the court majority had erred in its interpretation of a key statute related to land ownership and inheritance rights. He contended that under Jamaican law, which was applicable in this case due to Jamaica's status as a British colony at the time when Mr. De Cordova acquired his property there, real estate could not be passed on through intestate succession if there were no legitimate children or direct descendants involved. In such cases, according to Harlan’s understanding of Jamaican law, properties would revert back to the Crown rather than being inherited by collateral relatives like siblings or cousins. Therefore he disagreed with the majority ruling which allowed Howard (a cousin) to inherit from De Cordova who died without any legitimate children or direct descendants.