Where a foreign government purports to confiscate its citizen's assets although located within the United States, the Second Circuit has held that both federal and state courts must deny effect to the confiscation unless it is consistent with United States law and policy. This result obtains because such a confiscatory decree constitutes an "act of state" within the category of actions deemed by the Supreme Court in Sabbatino to necessitate a uniform federal rule.
International Conflict of Laws: Limitations Imposed on Effect American Courts May Give to Foreign Confiscations,
1966 Duke Law Journal
Available at: http://scholarship.law.duke.edu/dlj/vol15/iss3/10