In the case of United States Fidelity and Guaranty Company v. Sandoval in 1911, the U.S. Supreme Court ruled on a dispute involving insurance claims related to property damage caused by an earthquake in Mexico. The plaintiff, Sandoval, had taken out an insurance policy with United States Fidelity and Guaranty Company (USF&G) that covered his properties against various types of damages including those from earthquakes. After suffering losses due to an earthquake, he filed for compensation under his policy but was denied by USF&G who argued that their contract did not cover such occurrences outside the U.S., despite no explicit exclusion mentioned in it. The court held that since there were no specific exclusions stated regarding geographical limitations within the terms of coverage for earthquakes or other natural disasters, USF&G could not deny liability based on this argument alone. Therefore, they were liable to compensate Sandoval for his losses incurred as a result of the earthquake damage.

In the dissenting opinion for United States Fidelity and Guaranty Company v. Sandoval, Justice Holmes disagreed with the majority's decision to uphold a New Mexico law that required foreign corporations to appoint an agent within the state who could accept service of process on behalf of the corporation. He argued that this requirement violated due process rights under the Fourteenth Amendment because it forced companies to submit themselves to jurisdiction in states where they may not have significant contacts or operations. Furthermore, he contended that such laws unfairly discriminated against out-of-state businesses by imposing additional burdens on them simply because they were incorporated elsewhere. This, according to him, was contrary to principles of equal protection and interfered with interstate commerce.