In the 1917 U.S. Supreme Court case Oetjen v. Central Leather Company, the court upheld a principle known as "act of state doctrine". The case involved a dispute over ownership of hides that were seized during the Mexican Revolution by General Victoriano Huerta's regime from Johann B. Oetjen, who was working in Mexico for an American company at that time. After being sold to several parties, these hides eventually ended up with Central Leather Company in New Jersey. Oetjen sued Central Leather for recompense but lost his argument both in district and appellate courts before appealing to the Supreme Court. The high court ruled against him too on grounds that it could not question acts committed by foreign sovereigns within their own territories - this is what came to be known as act of state doctrine. The ruling essentially meant that U.S courts would not sit judgment on actions taken by other governments within their borders even if they appear unjust or violate international law standards; such matters are best left to diplomatic negotiations between nations rather than judicial intervention.

In the dissenting opinion for Oetjen v. Central Leather Company, Justice Oliver Wendell Holmes Jr., argued that the U.S. Supreme Court should not have jurisdiction over this case because it involved a political question rather than a legal one. He contended that the recognition of foreign governments and their actions is primarily within the purview of the executive branch, not judicial review. Therefore, he believed it was inappropriate for courts to determine whether or not Mexico's Carranza government had lawfully seized hides from German citizens during its revolution in 1914-15 - an issue at heart in this case. Furthermore, he disagreed with majority’s reliance on Underhill v Hernandez (1897) precedent which held that US courts must accept as valid acts committed by foreign sovereigns within their own territories; instead arguing each case should be considered individually based on specific circumstances surrounding them.