Underhill v Hernandez 168 US 250 (1897)

George Dunhill brought an action against Jose Manuel Hernandez for damages for refusal to grant a passport to leave Venezuela and confinement of the former in his own house by the latter while he was a military commander in Venezuela

The acts of a foreign government done within its own territory cannot be brought into judgement in the courts of this country Every sovereign state is bound to respect the independence of every other sovereign state and the courts of one country will not sit in judgement on the acts of the government of another done within its own territory Acts of a military commander in a foreign country representing the authority of the revolutionary party as a government that afterwards was recognised by the US cannot be made the subject of a personal action against him in the courts of this country