In The Apollon, Edon, Claimant (1824), the Supreme Court of the United States heard a case involving a French ship called L'Apollon. The vessel was seized by an American privateer during the Napoleonic Wars and brought to Baltimore for adjudication in 1814. In 1817, France filed suit against America claiming that they had violated international law by seizing their property without proper authorization from either country's government. After several years of litigation, it was determined that although there were some technical violations on both sides with regards to how the seizure occurred and who should have been notified first about it, ultimately neither side could be held liable as no actual harm had been done to either party due to this incident. As such, France's claim for damages was denied and L'Apollon remained in American hands until its eventual sale at auction in 1824.

In The Apollon, Edon, Claimant case, the Supreme Court was tasked with determining whether a French vessel captured by an American privateer during the War of 1812 should be returned to its original owners. Justice Johnson wrote a dissenting opinion in which he argued that under international law and treaties between France and America at the time of capture, it was not permissible for either nation to seize vessels belonging to citizens or subjects of each other. He further noted that even if such seizures were allowed under certain circumstances they must have been authorized by competent authority from both nations before being carried out. Therefore since there had been no authorization given in this particular instance he concluded that the vessel should be restored to its rightful owners without any compensation being paid for damages incurred during its seizure.