Essling v. Brubacher

How later courts describe this case

• noting and rejecting the contention that the act of state doctrine "has been sapped of its vitality and rationale" by the "Sabbatino Amendment," 22 U.S.C. § 2370(e)(2)
• defamation claim required determination of legality of loan allegedly arranged by plaintiff head of state
• an “inordinate delay” in State post-conviction process may render the State remedy ineffective
• Noerr-Pennington does not protect applications to governments of other nations
• rationale of Noerr-Pennington inapplicable to acts in foreign countries
• act of state argument successful