The case Verlinden BV v. Central Bank of Nigeria, 1982, revolved around the issue of jurisdiction in a dispute between a Dutch corporation and the Central Bank of Nigeria. The Dutch company sued the Nigerian bank in U.S federal court for breach of contract over an agreement to purchase cement. The Supreme Court was tasked with determining whether U.S courts had jurisdiction under the Foreign Sovereign Immunities Act (FSIA) even though both parties were foreign entities. In its decision, the Supreme Court held that FSIA did provide subject-matter jurisdiction over cases involving foreign states as defendants regardless if any party is American or not; however, it also emphasized that there must be some connection with the United States beyond just being filed here for personal jurisdiction to exist - which was lacking in this case.

In the dissenting opinion for Verlinden BV v. Central Bank of Nigeria, Justice White argued that the Foreign Sovereign Immunities Act (FSIA) did not grant jurisdiction to federal courts over cases involving foreign entities in all circumstances. He contended that FSIA should be interpreted as only providing a set of standards for determining when immunity should be granted to foreign states and their instrumentalities, rather than being seen as an across-the-board conferral of jurisdiction on federal courts. According to him, such broad interpretation could lead to potential abuses and conflicts with other nations since it would allow U.S. courts to adjudicate disputes between two foreign parties based solely on a tenuous connection with the United States or its citizens.