In the case of La Conception, The Spanish Consul was claiming a vessel that had been seized by the United States. The Supreme Court held that since Spain and the United States were not at war, there could be no legal justification for seizing a neutral vessel. Furthermore, it was determined that even if there had been an act of hostility against Spain by citizens of the United States, this would not have justified seizure as such acts are outside of governmental authority. As such, it was ruled in favor of The Spanish Consul and they were awarded possession over their vessel.

In La Conception, the Supreme Court was asked to decide whether a Spanish consul had the right to bring an action in rem against a vessel for damages caused by its negligence. The majority opinion held that he did not have such rights because his claim was based on foreign law and could not be enforced under American law. Justice Johnson dissented from this decision, arguing that it would be unjust to deny the claimant his remedy simply because of differences between American and foreign laws. He argued that since there were no applicable statutes or precedents governing this case, courts should look at principles of natural justice when deciding cases like these. Furthermore, he noted that if Congress intended for claimants with similar claims as those brought by the Spanish consul to be denied their remedies then they would have passed legislation making it so; however, no such legislation existed at the time of this case. Ultimately, Justice Johnson concluded that denying relief in this situation would lead to injustice and thus urged reversal of the majority's decision.