In the case of La Abra Silver Mining Company v. United States in 1899, the U.S Supreme Court ruled against La Abra Silver Mining Company, a Mexican corporation with American shareholders. The company had claimed that it was unjustly treated by Mexico and sought compensation from the U.S government under an 1868 treaty between Mexico and America which provided for claims by citizens of either country to be settled through arbitration. However, the court held that corporations were not "citizens" within the meaning of this treaty and therefore could not claim damages under its provisions. Furthermore, even if they were considered as such, their claim would still fail because it was based on actions taken by Mexican authorities within their own jurisdiction - something over which American courts have no control or authority.

In the dissenting opinion for LA ABRA SILVER MINING COMPANY v. UNITED STATES, Justice Harlan disagreed with the majority's decision to award damages to La Abra Silver Mining Company. He argued that there was insufficient evidence proving that Mexico had failed in its duty of providing protection to the company’s property during a civil war period. Furthermore, he contended that even if such failure could be established, it would not necessarily mean an international wrong had been committed by Mexico as per international law standards at that time. The justice also expressed concerns about setting a dangerous precedent where nations could be held liable for damages caused by insurrectionary forces within their borders despite their best efforts to maintain order and protect foreign interests.