Noyes Claim US v Panama General Claims Arbitration

1927 Noyes was attacked in a village, where adherents of the party in control of the government gathered for a meeting, the police in the spot had not been increased, there were just 3 policemen. The crowd became unruly under influence of liquor, and the chief of police drove to the place with reinforcements. The crowd blocked the car of Noyes. A person lurched against the car and the crowd smashed the windows, a policeman could stood in front of the car to protect him while he run away. The policeman remained with Noyes until the latter had got clear of the crowd. US demanded property losses

The mere fact that an alien has suffered at the hands of private persons an aggression, which could have been averted by the presence of a sufficient police force on the spot, does not make a government liable for damages under international law. There must be shown special circumstances from which the responsibility of the authorities arises; either their behaviour in connection with the particular occurrence, or a general failure to comply with their duty to maintain order, to prevent crimes and to prosecute and punish criminals. There were no circumstances at the present case