With its decision in Alfred Dunhill of London, Inc. v. Republic of Cuba, the Supreme Court has, for the third time in twelve years, rendered a significant if not landmark ruling on the act of state doctrine. Before 1964 the Court had not decided a case involving that doctrine for more than twenty years. During that intervening period many questions were raised in the learned writings on the subject, and the controversial decision, Bernstein v. N. V. Nederlandsche-Amerikaansche, etc., was decided by the Second Circuit Court of Appeals in New York.
John S. Williams,
The Act of State Doctrine: Alfred Dunhill of London, Inc. v. Republic of Cuba,
9 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol9/iss4/2