Oetjen v. Central Leather Co.

Background

A Mexican hide dealer who fled the city after a takeover left large consignments of hides that were seized by General Villa in Torreon as a military contribution and sold on January 3, 1914, to a Texas company. That company brought the hides into the United States and kept them. The original owner’s assignee sued in New Jersey to recover the hides. Lower courts ruled for the buyer, and the case reached this Court because the claimant argued the seizure violated the Hague Convention rules against confiscating private property.

Reasoning

The Court considered whether U.S. courts can overturn a sale made in Mexico by a military authority during the Mexican revolution. It explained that questions about recognizing foreign governments and their acts are for the political branches of the U.S. government, not the courts. The Court noted that the United States later recognized Carranza’s government, and that such recognition validates the acts of that government from its start. For these reasons, and because courts should not sit in judgment on the internal acts of another sovereign within its own territory, the Court would not reexamine the seizure or sale made in Mexico.

Real world impact

Because U.S. courts will not retry the validity of actions a foreign government takes inside its territory, the buyer’s title stands and the prior owner’s claim fails. People who buy property from a foreign government after a seizure may keep it in U.S. courts, while owners seeking redress must pursue remedies in that foreign country or through diplomatic channels.