In the case of Volkswagenwerk Aktiengesellschaft v. Schlunk, 1987, the U.S. Supreme Court ruled that service of process on a foreign corporation's wholly owned subsidiary within the United States was sufficient to bring the parent company under jurisdiction in an American court. The decision arose from a wrongful death suit filed by Joseph Schlunk against German automaker Volkswagen and its U.S.-based subsidiary after his son died in a car accident involving one of their vehicles. When served with papers for litigation, Volkswagen argued it could not be sued because it had not been properly served according to international law requirements as outlined in Hague Service Convention treaty - which requires documents to be sent through central authorities designated by each country party to this agreement for transmittal directly to individuals abroad. However, Justice Byron White writing for unanimous court held that since VW’s US-based subsidiary was so integrated into operations (essentially acting as its agent), serving them effectively notified parent company too; thus bypassing need for international service procedure.

In the dissenting opinion for Volkswagenwerk Aktiengesellschaft v. Schlunk, Justice O'Connor disagreed with the majority's interpretation of the Hague Service Convention and its application to this case. She argued that service by mail should not be considered equivalent to service through a domestic agent under Article 10(a) of the convention. According to her, allowing such an interpretation would undermine one of the primary purposes of international agreements like these: predictability in legal proceedings across borders. Furthermore, she believed that it was inappropriate for U.S courts to unilaterally interpret ambiguous provisions in international treaties without considering how other signatories might interpret them or seeking clarification from appropriate authorities on their meaning and intent.